Under the first strand of reasoning in Myer Emporium (transfer of right to future interest on loan for net present value):

a. All gains from commercial transactions entered into by taxpayers who are otherwise in business will be ordinary income.

b. Interest payable over more than one year is only deductible in the year to which it is properly referable.

c. The change in the share ownership of the company was a critical factor in establishing that the purpose of the company had changed.

d. A profit from a transaction outside the ordinary course of the taxpayer's business may be income if the taxpayer had a significant profit making purpose when entering into the transaction.