One of the factors indicating a trading intention is where some modification is made to an asset before selling it. The idea is that by incurring expenditure and undertaking the work, the asset is brought into a more marketable state, thereby attracting potential buyers:

‘The profit made by the venture arose, not from the mere appreciation of the capital value of an isolated purchase for resale, but from the expenditure on the subject purchased of money laid out upon it for the purpose of making it marketable at a profit. That seems to me of the very essence of trade.’ (IR Commrs v Livingstone at 542)

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