Mailings Review View AaBbCcDc AaBbCcDc AaBbCc AaBbCc AaBlAaBbC 1 Normal 1 No Spacing Heading 1 Heading 2 Title Paragraph 2 3 Styles 6 Subtitle Question 2 Apple Holdings Pty Ltd was formed eight years ago by Jonathan and Sonya, who were the initial shareholders and directors. Jonathan and Sonya had for many years been involved in property development. Seven years ago, Apple Holdings purchased two properties in an area where there was extensive real estate development. For six years the properties were used as orchards and the properties were improved for that purpose. Owing to unforeseen circumstances, the orchards proved to be unprofitable and there was talk of plans for a zoning change in the near future. This would mean the properties could only be disposed of in 100 hectare lots instead of 25 hectare lots. Apple Holdings therefore arranged to subdivide the land up into 25 hectare lots and sold the whole property to one purchaser. The Commissioner assessed Apple Holdings on the gross receipts. Required: Apple Holdings is concerned about the Commissioner's assessment and seeks your advice on whether, and how, the amount received could be characterised as assessable income. In your response, you should consider whether the sale is an isolated transaction, a realisation of an asset, an extraordinary transaction- and the relevance of profit motive. You must support your analysis with reference to relevant cases. Click or tap here to enter text. 20 marks 112 pause