Heather runs a chain of florist shops. Over the years, she has purchased 8 premises for her business. Her main criterion in selecting each of the premises was where flower sales were most likely to be maximised, though she also liked to factor in the potential capital growth of each premises.

During the current tax year, Heather decides to develop one of her florist premises as property in the area has lately become much more valuable. This involves getting council approval, and building a five-storey apartment block over the existing florist shop. The developed apartments are sold individually to the public. As Heather is a busy person, she contracts a builder to organise the building of the apartment block (and left most of the important construction decisions for them to make) and a real estate agent to organise all of the selling of the apartments.

Discuss whether the sale of the apartments will generate ordinary income