Sunil is 64 years old. For many years he owned a $2 shop which he has operated in a regional shopping centre. Sunil bought the shop in December 1986 when he acquired it at a cost of $120,000. However, because of the long hours involved in running the shop he decided to reduce his operations, Sunil talked to a real estate agent in september 2020. The agent advised that under current market conditions the shop, if sold as a single unit, would fetch $600,000. Sunil decided not to sell the shop as a single unit. Instead, he decided to divide the shop into four mini-shops and to sell them at $1,200,000 ($300,000 each). The cost of doing this was $70,000 in total. He began subdividing the shop in November 2020 and completed the sub-division in March 2021. After the sub-division was completed, Sunil sold each of the mini-shops.

Required:

Citing all relevant legislation and case law, discuss whether Sunil would be assessable on the sale of the four mini shops. Do not calculate Sunil's tax liability.