for a construction company and began to search for rundown houses in her neighbourhood that she could buy at a low price. Her objective was to bring her houses up to code li$.$e$.,$ in accordance with building regulations$)$ and then rent them to individuals who could not afford adequate housing.

Saba charged just enough rent to cover the expenses of each house. By March $2022,$ she owned five houses that were rented to five families. She went back to work as a part$-$time plumber while she took courses toward a university degree in social work.

Saba came from a large family, many members of which were involved in construction. She called on her family for help when her tenants needed services, and they gave her a family discount for their services.

In June $2023,$ she learned that the owner of two low$-$rise apartment buildings in the neighbourhood had died. The two apartment buildings were vacant and in very poor condition. The executor of the estate was receptive to a quick sale. Saba offered $$250,000$ cash for the two buildings and the large parking lot between them. The offer was accepted.

As this was a much larger project than the single family homes she had been working on$,$ she enlisted the aid of her father, an experienced contractor. He agreed to be the general contractor for the project.

In August $2023,$ a major software company announced it was going to move its Canadian headquarters into the neighbourhood within two years.

In September $2023,$ Saba received an unsolicited offer of $$1\mathrm{.}5$ million for the two apartment buildings and the parking lot. The purchaser intends to construct a new condo building to house the workers but has agreed to maintain a quarter of the units for low$-$income families.

The offer requires Saba to take back a $$1$ million first mortgage on the property. The mortgage will be repaid in four annual instalments of $$250,000$ each, beginning in $2024.$ The cash down payment would be $$500,000.$

Required: Saba has sought your advice about the income tax treatment of the sale of the two apartment buildings and parking lot. Provide the necessary advice, including the calculation of the minimum amount of taxable capital gains that would be required to be included in Saba's net income for the year of sale on the assumption that the properties purchased are capital property.