The paper considers the circumstances in which a small to medium land subdivision may qualify as a mere realisation and when the project may become a profit making undertaking or business.

It looks at the issues that are relevant if the property was not originally acquired with the intention of reselling at a profit or development as, in those situations, the profit will be ordinary income irrespective of how long the property is owned or whether the profit is generated from the precise means that were contemplated at the time of acquisition.

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