Derek Shepard purchased a 5,000 acre ranch in Montana. He tried unsuccessfully for 15 years to raise buffalo and to sell buffalo meat to a chain of health food stores. He offered the ranch for sale, but was unable to find a suitable buyer because of the size of the property. He decided to market the property in 50 pieces to hunting enthusiasts as private fame reserves. He advertised in magazines read by hunters and outdoor enthusiasts. During the current year, he was able to sell 10 parcels at a net profit of $400,000. What is the proper tax treatment of this gain(LTCG, ordinary income,etc)?