Question juridique clé
Whether the remise could be treated as business assets of the taxpayers despite third-party ownership.
Solution extraite
No. The remise could not be booked as business assets because the land and building belonged to the taxpayer's mother and no valid real right in favor of the son was created.
Motifs extraits
Business assets generally require civil-law ownership; the limited exceptions recognized by case law did not apply. Mere actual possession and exclusive use were insufficient for a long-term building.