While I can see a literal application of the rules of 197(d)(1) [and (d)(2)] and reg. 1.197-2(b)(6), somehow this set of facts does not seem to me to be what those authorities are meant to encompass. They speak of
... any composition of market, market share, or other value resulting from the future provision of goods or services pursuant to contractual or other relationships in the ordinary course of business with customers. Thus, the amount paid or incurred for customer-based intangibles includes, for example, any portion of the purchase price of an acquired trade or business attributable to the existence of a customer base, a circulation base, an undeveloped market or market growth, insurance in force, the existence of a qualification to supply goods or services to a particular customer, a mortgage servicing contract (as defined in paragraph (c)(11) of this section), an investment management contract, or other relationship with customers involving the future provision of goods or services.
. Those are all long-term and general in nature. If part of the purchase price involves a customer base, sure, it fits. And that may indeed be the facts here. But if, in addition to that general customer base, existing contracts that will almost all be completed in 2021 are specified as separate assets being acquired, it seems they are tantamount to receivables. In fact, I wonder if, as an accrual-method taxpayer, they are receivables. That's a separate question to be considered under 451 and the all-events test, etc.
And if somehow these contracts are viewed as 197 intangibles (which I doubt), then look into whether they are considered disposed of under 1.197-2(g)(1)(ii) or some other authority.