Background

Two property owners filed two cases before the First Instance Tax Court against the competent tax department requesting the annulment of decisions that compelled them to pay taxes after the estimation of their net profits for selling two pieces of agricultural land, which was a multiplicity of their real estate actions within ten years.

The court issued a ruling cancelling the tax department decision, the invalidity of the estimation of their profits on the sale of the agricultural land, and the annulment of the tax assessment.

The defendant filed an appeal. The court cancelled the appealed ruling, rejected the appeal and confirmed the tax department decisions.

Decision

Each of the plaintiffs filed an appeal in cassation and the court joined them (8219 and 8218).