Hypothetical Facts: Mr Prigozi, a trained builder and quantity surveyor, left Trappistan, where he was born and

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Hypothetical Facts: Mr Prigozi, a trained builder and quantity surveyor, left Trappistan, where he was born and emigrated to South Africa in 2010. He states that he had some concerns with the government and some disagreements with the local mayor where he lived. He purchased a house for R1 000 000. 00 and has lived in South Africa continuously for 12 years. Mr Prigozi enjoys cooking and producing social media content. His favourite food is hotdogs, and he has, in the past, made food for various social media influencers. He makes no money from these pursuits. He is the chairperson of an NPO called PM-Contractors in South Africa, which assists prisoners in obtaining employment. A private security company in South Africa (Wagon Security Solution) employs Mr Prigozi as an advisor on security matters. His annual salary is R 900 000. 00. On 1 March 2022, Mr Prigozi inherited a shooting range called 'The Monday Blues' located in Johannesburg. The Monday Blues is extremely profitable and situated in a good location. Mr Prigozi enjoys shooting weapons but has a previous criminal conviction after he assaulted someone and stole their shoes. He, thus, is not a fit and proper person to own a shooting range in South Africa. Mr Prigozi supplements his salary through various business activities. He produces military clothing items under the name of 'InvisiChic', which his clients order from his website, Internet Clothing Agency. Mr Prigozi bought a farm called Fruitopia in 2015 for R2 000 000. 00. This farm was a going concern close to the rapidly expanding city of Durban on which the previous owner planted cabbages. However, the previous owner struggled as there were always issues with the water supply to the farm, causing the crops to fail every year. Mr Prigozi had never farmed before but attempted to farm on the property for several years. He employed two people who planted cabbages, but this farm had no water. Mr Prigozi's farming attempts were disastrous, and he made no profits in any year thereafter. He eventually gave up in July 2020 and attempted to sell the farm for R 6 000 000. 00, but there were no interested parties. Mr Prigozi states that he is open to any suggestions on how he could get rid of this land. He sold some sand that was mined on Fruitopia for building purposes to a local building supply company called Get and Takemore (Pty) Ltd (G&T). G&T approached Mr Prigozi and asked to remove as much sand as they wanted for a specified amount. Mr Prigozi, however, employed one person to monitor the removal of the sand, and he charged G&T per ton removed. Mr Prigozi also owns shares in a South African company listed on the Johannesburg Stock Exchange called Wagno Ltd. Mr Prigozi's receipts and accruals (2022/2023) included the following amounts: 1. Mr Prigozi was forced to immediately sell The Monday Blues on 12 September 2022 for R5000 000. 00. The sale price was made up as follows: i. Property and building : R3000 000. 00 ii. Goodwill : R1000 000. 00 iii. Furniture/computers : R 500 000. 00 iv. Stock (ammunition) : R 500 000. 00 - this stock was bought for R800 000. 00. 2. Mr Prigozi decides that he will never be able to sell Fruitopia and decides that it may be a good idea to develop the land by rezoning the land from agricultural to residential and then subdivide the property and build houses on these properties. He employs legal practitioners (R100 000. 00) and a surveyor (R50 000. 00) to attend to the subdivision, an estate agent (R100 000. 00) to market and sell the houses and some builders to construct the houses (R250 000. 00). He also paid a cash amount to the local councillor (R100 000. 00) as an incentive to ensure that the municipality would approve the rezoning. Mr Prigozi sells 50 houses and makes a profit of R12 000 000. 00. The full amount was paid to him on 12 December 2022; 3. Wagno Ltd declares a dividend on 16 December 2022 of R75 000. 00; 4. Mr Prigozi travelled to Las Vegas for his birthday and gambled in the MerryMercenary casino. He actually won the equivalent of R500 000 on 3 January 2023 while playing Roulette; 5. Mr Prigozi states that he wants to retire and sells his house in South Africa, where he lived for 12 years. He sold the house and signed the sale agreement on 26 February 2023. The sale agreement contains a suspensive clause as the purchaser, Mr Valary Garmisin, needs to obtain a bond from a bank in the amount of R7 000 000. 00. Valary secures the bond on 12 March 2023, and the house is sold for the amount is R8 000 000. 00. Mr Prigozi received this amount on 30 June 2023; 6. The amount received from G&T for the sand for the 2022/2023 year of assessment amounted to R120 000. 00. Mr Prigozi paid the employee overseeing the removal of the sand R36 000. 00 during this time for his services; 7. InvisiChic sold clothes in the amount of R150 000. 00 during the 2022/2023 year of assessment. Its expenses (material, salaries, fees, insurance) amounted to R 200 000. 00. Mr Prigozi purchases a house in Hermanus and retires to a life of blogging on YouTube. Required: You are required to explain, giving full reasons, whether the above amounts will be included in Mr Prigozi's gross income for the 2022/2023 year of assessment. You are also required to state why these amounts may not be included in his gross income calculation and give full reasons for the tax treatment of these amounts. Include reference to primary sources, case law and other credible sources in your answer. Remember to logically and separately deal with all the amounts, including the amounts received from his employment, the sale of The Monday Blues (Property and building, Goodwill, Furniture/computers, Stock), the development of Fruitopia, the dividend received from Wagno, the gambling winnings from The MerryMercenary, the sale of his house, G&T for the sale of the sand and the InvisiChic venture