WFB Builders is a partnership formed by two construction companies (neither of which is a C corporation) using a calendar year tax year. WFB builders has been engaged in numerous other projects over the last several years such that it has had gross receipts of at least $35 million per year since 2015. In October 2019, WFB entered into a contract with O Development Co. to build a 25-story apartment building with at least 150 apartments and various amenities for the residents such as a fitness center, community room, etc. There will also be space for a coffee shop on the ground floor. The plans for the building show that the coffee shop will take up only 5% of the total floor space in the building. The total contract price for the construction is $100 million. Construction is to commence in November 2019 and the building is to be completed in June 2021. At the end of 2019, WFB estimated that 75% of the contract costs will be attributable to the actual residential units in the building, another 17% of the costs will be attributable to the common areas and amenities for the residential units, and 8% of the costs