Code Sec. 1237 provides that if there is "no other substantial evidence" that a taxpayer holds real estate primarily for sale to customers in the ordinary course of business, the taxpayer is not considered a real estate dealer holding it primarily for sale merely because the taxpayer has subdivided the tract into lots or parcels and engaged in advertising, promotion, selling activities, or the use of sales agents in connection with the sale of lots in the subdivision. A developer who buys a farm for $1 Million and subdivides it into one hundred buildable lots, and improves the property with road, water and sewer at a cost of $500,000 and sells the property to a home builder for $2 Million eighteen months later, generates what type of income? A) Passive income. B) Portfolio Income C) Ordinary Income. D) Long Term Capital Gain. E) Short Term Capital Gain