§1812

After concessions by the parties,1 the only issues for decision are (1) whether petitioner made a timely section 1812 election for the film series production costs to be treated as currently allowable expenses and (2) whether the film series expenses qualify for a section 181 deduction.

ounting for U.S. tax purposes. In Tate & Lyle, Inc. & Subs. v. Commissioner, 103 T.C. 656, 662 (1994), we agreed with respondent that the terms "gross income" and "method of accounting" as used in sec. 267(a)(2) meant for U.S. tax purposes. - 31 - §§1812(c)(1), 1881. [Tate & Lyle, Inc. & Subs. v. Commissioner, supra at 661.] Following this rationale, the Commissioner argued in Tate & Lyle, Inc. that even without section 267(a)(3) and section 1.267(a)-3, Income Tax Regs., the taxpayer's interest

1812(b)(3), 100 Stat. 2834. The legislative history accompanying the technical correction provides the following justification for the amendment: The definitions of term loan and demand loan in section 7872 appear to treat loans with an indefinite maturity as term loans. However, it often is impractical to treat a loan with an indefinite matur