Kernrechtsfrage
Whether the property gains tax lien had lapsed because the request for registration was filed too late.
Extrahierter Entscheid
The lien right had not lapsed because the statutory three-month registration period ran from tax due date and the lien was entered within that period.
Extrahierte Begründung
The tax became due upon service of the assessment notice; the lien was registered on 12 August 1991 after the 16 May 1991 assessment, thus in time under § 59(4) StG.