amir is an art collector and has collected a number of paintings over the last 20 years as well as having acquired a number of inheritance . Amirta was recently made redundant and decided to set up a business. in oder to raise money for her new business she sold a number of paintings from this collection . each one raised between 5000 and 60 000. The paintings were sold through specialist paintings auctioneer . Amir has not declared these transaction as income as she believes that the proceeds from selling paintings are not taxable .

required - advise amrita on whether or not she is correct in believing that her painting sales are not taxable . Your advise should include reference to the badges of trade and their application to this case