Key legal question
Whether a loss arose on transfer of the property from business assets to private assets and is deductible in the 1999/2000 direct federal tax period.
Extracted holding
No deductible transfer loss could still be taken into account in the 1999/2000 tax period; private-capital losses are tax-irrelevant, and any value loss should have been reflected earlier by depreciation while the property was still business assets.
Extracted reasoning
Depreciation is allowed only on business assets. If the property had already lost value by 31 December 1996, that loss had to be recognized in the earlier assessment period. Once the property was no longer business assets, a special depreciation could no longer be claimed.