Key legal question
Whether the gain from the sale of the condominium unit was taxable under direct federal tax as business asset gain or exempt as private asset gain.
Extracted holding
The unit remained business property after the 1989 transfer, so the sale gain was taxable as income from self-employed business activity.
Extracted reasoning
The unit continued to serve the business purpose of the spouses' economic unit: it remained listed as a business property in tax filings, secured the construction loan, and the wife assumed the loan jointly and internally. No convincing transfer to private assets was shown.