In May 2020 Bernard, a self-employed plumber, and his son Gerald, a self-employed electrician, purchased 1,000 empty barrels from a Scottish whisky distillery. The barrels were over 100 years old and were of no further use to the distillery. Bernard and Gerald sawed the barrels into halves and sold them to several local garden centres for use as ornamental flower tubs. Bernard and Gerald paid £10 per barrel to the distillery and sold a half-barrel for £8. Three-quarters of the barrels were sold by Bernard and Gerald in the summer of 2020 and the remainder in the summer of 2021.

You are required:

To prepare a list of relevant points for consideration prior to writing a report to Bernard and Gerald on the liability to income tax on the profit generated by the venture.