Buffalo Bill purchased a 5,000 acre ranch in Montana. He tried unsuccessfully for 15 years to raise buffalo and to sell buffalo meat to a chain of health food stores. He offered the ranch for sale, but was unable to find a suitable buyer because of the size of the property. He decided to market the property in 50 parcels, each approximately 100 acres, to hunting enthusiasts as private game reserves. He advertised in magazines read by hunters and outdoor enthusiasts. During the current year, Mr. Bill was able to sell 10 parcels at a net profit of $400,000.

1) How is the gain treated 1231, capital, or ordinary? explqin