Kernrechtsfrage
Whether the conversion costs for turning a kindergarten into a residential house are deductible maintenance expenses.
Extrahierter Entscheid
The conversion constituted a qualitative improvement and a new use of the property; the claimed costs were not deductible as maintenance.
Extrahierte Begründung
Maintenance preserves existing value, whereas the works here transformed the building into a different, better-equipped residential property. The court treated the renovation as a whole and qualified the spending as value-adding, not merely preserving.