Questione giuridica chiave
Whether the gain from selling the co-owned property share was private asset management or professional real estate trading income.
Decisione estratta
The transaction showed multiple converging indicators of professional real estate trading, so the gain was taxable as income from self-employment.
Motivazione estratta
The court relied on joint investment with construction professionals, heavy third-party financing, substantial improvements, short holding period, and reinvestment. Even though the transaction was isolated, the overall circumstances showed an intent to profit through the real estate market.