Len Jamal bought a parcel of land in 1998. It was his intention that he would reallocate his proprietorship business to the land someday. However, the city continues to delay issuing permits to landowners and eventually Len purchased another property to reallocate his proprietorship business to. He held onto the land for a number of years bus has now decided that he needs the cash and will sell the property. The details related to his purchase of the land are set out below.

Purchase Price: $4,000; Purchase Date: May 21, 1998

Len has received an offer from an acquaintance to purchase the land. The payment terms are set out below and are considered to represent fair market value.

Purchase Price: $160,000; Purchase Date: October 1, 2018

Payment terms: $40,000 down payment on purchase date; $20,000 payable on January 1 each year for the period of January 1, 2019 through January 2024 inclusive. Interest: Interest is payable at 6% annually on the unpaid balance.

Len is uncertain as to whether the disposition is on account of capital or income.

You have been asked to compare income tax consequences to Len of this sale if the sale is on account of capital, and, alternatively, if it is on account of income. Do not calculate the interest income. Ignore the consequences and calculation of interest income.