Facts
The appellants [A.X.] and [B.X.] , who operate a personal company [Y.] , sold two agriculturally used plots of land in the gravel extraction zone in [E.] to [Z. AG] in 2004. At the same time, they acquired from [Z. AG] nine parcels of excavated and recultivated land. The tax commission [J.] only recognized the claimed replacement acquisitions in the amount of the agreed repurchase price and did not allow the value adjustment for the land [T.] .
The appellants filed an appeal against this decision and requested that the value adjustment for the land [T.] be recognized and the replacement acquisition in the amount of CHF 1'625'388.-- be confirmed.
Considerations
The Federal Court dismissed the appeal. It found that the value adjustment for the land [T.] is not justified, as the appellants have not proven that a depreciation has occurred.
The Federal Court also rejected the replacement acquisition, as the sold plots of land were not operationally necessary and…