This can catch a one off transaction. Isolated transaction , completed unconnected with any sort business can result in tax liability under cb4. We look for is tax payer purpose at the time they bought the asset. Perfectly fine to have no purpose when you buy an asset. If you find an asset and find out that you are selling it. You only think about disposal where the taxpayer makes a gain as well. Most thing we dont make gain on. We were interested in the purpose at the time the property is acquired. That purpose has to be the dominant purpose. If you buy smtg, thinking that your going to use it but some point in future you sell it, then it is not the dominant purpose. If you buy smtg thinking i will sell it but i'm going to use it in the mean time then disposal is morel likely your dominant purpose. we looking for the main purpose here. As you see it is a subjective test