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A shopping centre operations business pays $ 1 0 0 , 0 0 0 for a call option on a parcel of land intending to
A shopping centre operations business pays $ for a call option on a parcel of land intending to build and operate a new centre. However, it abandons its plans to own a new centre and sells the option to a land investment company for $
Whis is the better view?
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The entire $ is ordinary income from a business of trading in land.
All commercial gains are ordinary income.
The entire $ is a capital receipt and not ordinary income. This is an extraordinary transaction outside the ordinary course of business and lacked a profit motive at the beginning.
The $ profit is ordinary income. This is profit from an isolated commercial transaction that had a profit motive from the start.
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