Which one of the following statements is incorrect? a. The cases of Applegate and Jenkins established that 'permanent' in the context of 'permanent place of abode' does not mean everlasting. b. The Full High Court held in FCT v Myer Emporium that the receipt in question was not ordinary income as it was outside the taxpayer's ordinary business. c. Income from property includes interest, rent and dividends. d. To be ordinary income, an amount must be in money or capable of conversion into money. e. Interest is an undefined term in the ITAA36 and ITAA97 and it is given its ordinary meaning for tax law