14. Factors considered in determining quality of receipt.

In the decided cases the courts have had regard to various factors1 in determining whether the proper nature of an item of receipt is income.

If an item recurs or is likely to recur annually or repeatedly to form a series, that is an indication of its quality as income2.

The price received on the disposal of a fixed asset of a kind in which it is not the business of the particular taxpayer to deal is generally a capital receipt3. A sum received for a consideration affecting the whole structure of the taxpayer's profit-making apparatus is usually capital4; however, if