The Paris Administrative Court of Appeal decided, on 24 February 1994, that the income derived from the sale of shares must be treated, in certain cases, as professional income instead of industrial or commercial earnings. In this case, the plaintiff was a taxpayer who was a board member for multiple companies and who, in the context of efforts for the success of an acquisition, had bought and resold some shares of the aforementioned companies. The Court treated the income derived from such operations as professional income, the taxpayer's patrimony increase corresponding to the counterpart of his efforts to make the acquisition possible.

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