On 10 September 2021, Michelle purchases a 10-year annuity from the Retirees Gold Ltd (RGL). Under the agreement, Michelle pays a lump sum amount of $1 million, and in return RGL would pay her $24,000 per year over and above Michelles $1 million investment. On 16 September 2021, Michelle sells the right to receive the annual payments to Alex for $210,000.

Required: Advise Michelle of the income tax consequences on receipt of $210,000 from Alex. Cite relevant legislation and cases in support of your answer.