Jim had always wanted to own and run a bed and breakfast (where guests pay to stay in overnight accommodation and receive breakfast the next day). About 10 years ago, he was considering purchasing a certain block of land suitable for running a bed and breakfast, which was situated about 30 km from Melbourne. At the time, a friend had mentioned to him that with Melbourne growing, in the future, this land might be worth a lot of money as Melbourne expands. Although Jim at the time was not motivated primarily by making money through the land rising in value, he still liked the idea that he could make a substantial profit from the land appreciating. He subsequently purchased that block of land, built a suitable building on it, and ran it as a bed and breakfast. After 10 years, Jim wishes to cease running the bed and breakfast, and enter into a different career. Luckily, the land had appreciated substantially in value. Rather than just sell it, Jim first demolished the bed and breakfast building, subdivided the land, and build roads on the land, as well as ensured that each block had gas, electricity and sewerage connections. He actively participated in this process. He then arranged for a real estate agent to sell each block

Required:

 Discuss whether the sale of the blocks of land will generate ordinary income (citing authority where appropriate)