Sunil is 64 years old. For many years he owned a $2 shop which he has operated in a regional shopping center. Sunil bought the shop in December 1986 when he acquired it at a cost of $120,000. However,...

Sunil is 64 years old. For many years he owned a $2 shop which he has operated in a regional
shopping center. 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 each ($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 subdivision was completed, Sunil sold
each of the four 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.