ContractOctober 21st, 2020
FiledOctober 21st, 2020than four separate agreements each for one building solely to take advantage of the de- ferral obtained under the 10-percent method. Consequently, to clearly reflect the tax- payer’s income, the Commissioner may re- quire C to sever the agreement into four sep- arate contracts under paragraph (e)(2) of this section because the buildings are independ- ently priced, the agreement provides for sep- arate delivery and acceptance of the build- ings, and a reasonable businessperson would have entered into separate agreements for these buildings.