Kernrechtsfrage
Whether EKC credits from June to August 1994 constituted realized taxable income
Extrahierter Entscheid
No. Because the banking commission's payout ban made the claims unenforceable and unavailable for disposal, the credits were not realized income during that period.
Extrahierte Begründung
Realized income requires actual receipt or a fixed claim over which the taxpayer can dispose. Here, the general payout prohibition blocked all ordinary payment channels, so the taxpayer could not effectively access the credited amounts; mere formal maturity was insufficient.