Which of the following statements most accurately describes the gain from the sale of property that is substantially appreciated at the time of sale?
(1) it is never passive activity in gross income
(2) It is passive activity gross income if the property was used in a passive activity for 20% of the taxpayers holding period
(3) It is passive activity gross income if the property was used in a passive activity for the 12 months immediately proceding the date of disposition
(4) It is always passive activity gross income