An intention to dispose of land at a profit sometime in the
future, does not automatically entail an intention to trade (CIR v
Reinhold [1953] 34TC389).
Land may be acquired as a capital asset in the knowledge that
it will appreciate in value and realise a 'profit' one day on
disposal.
The fact that, in the meantime, it may not produce investment
income, is not conclusive (Marson v Morton and Others [1986]
59TC381).
You need to establish not just a profit seeking motive but a
trading intention.
