In the case of continuous real estate trading, the income obtained is not taxed as an increase in value but as a commercial gain. Sales made within a commercial organization, even if a single sale has been made, will be considered as commercial gain, if more than one sale has been made without a commercial organization (more than one in one year or one in each year) it will be necessary to determine the purpose for which the sale was made.
In this case, trading transactions for profit-making purposes should be evaluated within the scope of commercial gain, while trading transactions for personal needs or for the protection of wealth should be evaluated within the scope of increase in value gain. At the same time, if such gains are earned by a business entity, the income is taxed as business income. The income obtained from the sale of the land purchased and acquired by Trampas in part or in whole within 5 years from the date of acquisition by being parceled and sold in this period or later years are taxed as commercial gain.