Can contracts count as goodwill?

I've just incorporated a partnership of estate agents as a limited company at the following approximate values: Goodwill (net of personal element) - £60k, Ongoing Contracts - £100k, fixed assets/website - £5k. HMRC have accepted the CG34 so all hunky dory. Just one thing nags at me. In their letter, HMRC "confirm acceptance of the proposed value of goodwill of £165k". Is it normal for them to confuse goodwill with the total value or can we get away with treating it all as goodwill?

In my pro-forma CGT calcs I did not claim ER on the contracts as they were less than  a year old (being pending instructions to sell property, etc). Therefore they will suffer CGT at 28% (sadly the goodwill element has to come first in the CGT queue and uses up the rest of the ex-partners basic rate bands). If we can treat them as goodwill and claim ER, that will reduce the CGT bill considerably.

Am I right to treat the contracts as separate assets or is there a loophole here? They were all pretty much certain to turn into fees as at the incorporation date (but not earned then as contracts had not yet been exchanged).

We're also thinking of claiming s165 gift relief on the contracts. This would save tax if they are happy to retain profits in the company and split the divs 50/50 (they are husband and wife so he can give her half the shares as a gift). Obviously we don't want s165 on the goodwill. However, I read that HMRC are reluctant to allow s165 on only some of the assets in an incorporation and insist on either all of them or none at all. Is that correct or are they more likely to allow it in practice?

Chris