Where a tract of land is purchased with the intent of selling subdivided lots or parcels, the cost or other basis shall be equitably apportioned to the several lots or parcels and made a matter of record on the books of the taxpayer. To the extent that any gain derived from the sale of any such lots or parcels constitutes taxable income, it may be reported as income for the tax year in which the sale is made. This rule contemplates that there must be a measure of gain or loss on every lot or parcel sold, and not measured on the entire tract as a whole. The sale of each lot or parcel must be treated as a separate transaction and gain or loss computed accordingly.
16.26 Ark. Code R. 51-404(a)(1)