Required: Ignoring capital gains tax, discuss whether the sale of the land has generated ordinary income under Australian Income Tax Law. Imp Pty Ltd is an importer of quality electrical goods. It purchased its current premises in Brunswick 20 years ago. It chose the premises location primarily because it would be a convenient location for its workers. Although Imp’s plan was to hold on to the premises long-term, it also chose the location because it considered the possibility that if it did sell the property, the location was likely to benefit from a substantial capital gain. Since the COVID-19 pandemic, working from home has become more common. As a result, Imp wishes to sell the car park, which is a portion of its Brunswick premises. To do so it demolishes the multi-level car park, gets council building approval for a multi townhouse development, and subdivides the total land it owns into two lots (one for what was previously the car park, one for the remaining portion which Imp intended to keep). Using a real estate agent, Imp then sells this portion of the land to a developer for $6 million.