Farming income on land held with a view to development

[Incredulum]

An active property developer company with a trade of property development has a piece of land which has been held for many years. This gives rise to income from crop sales, and subsidy payments from the rural payments agency.

It would be helpful if it could be argued that such income was any case other than trading income - either miscellaneous or income from land.

Any hope?

[maths]

Nope.

Farming constitutes the carrying on of a trade (ITTOIA 2005 s 9).

Farming means the occupation of land wholly or mainly for the purposes of husbandry (ITA 2007 s996). Husbandry includes the growing crops.

[Incredulum]

Thanks - CTA09 s36, but yes. Just trying to clutch at straws.