Questione giuridica chiave
Whether the loss from the third property sale had to be allocated to tax year 2006 for inter-cantonal purposes.
Decisione estratta
The loss had to be taken into account in 2006; the relevant realization date is the date of public deed for the sale contract, not the land-register transfer date.
Motivazione estratta
A harmonized and coherent temporal rule is required in inter-cantonal taxation. For property gains and losses in the monistic system, realization follows the binding contract by public deed; the cantonal rule to the contrary could not override federal law and inter-cantonal double-taxation principles.