Stephen is a commercial property investor who currently owns a number of commercial rental properties in the Fyshwick area. He also operates a real estate agency specialising in leasing commercial property to business tenants. He was never interested in property development. However, in May 2017 he purchased a very old building used as a motor repair shop in Braddon (close to the Canberra CBD) for 1.5 million dollars ($1.5m). A friend told him that Braddon was an up-and-coming area and a good place to build apartments and make a lot of money from selling them. Stephen wants to get in on the action but the Bank won't give him a loan to build a 50-unit apartment block on the site. He has a great idea. All of his current investment properties are rented out to business tenants on long-term leases who pay him rent on a monthly basis. He assigns the rights to the rent from the investment properties to the Bank for a period of 5 years in return for the Bank paying him a lump sum of 10 million dollars ($10m). He receives this amount in July 2018. Stephen builds the apartments on Braddon site and then sells all of the apartments for a total of 20 million dollars ($20m) in June 2021. At the time the construction commences the value of the Braddon site is 4 million dollars ($4m). The apartments cost 10 million dollars ($10m) to build.

Required: Using relevant legislation and case law, advise Stephen whether any of the amounts he receives are assessable income in the 2019 and 2021 income years.