Where the acquisition of a certified production is financed by the issue of a non-interest bearing note, the note must be discounted to reflect its present value in determining the capital cost of the production.
Discussion of the requirements for a taxpayer to be considered to be the owner of a film.
"A disposition of the film or tape will be considered to take place where the investor grants to a person or persons the right to distribute or otherwise exploit the film or tape in markets representing most or all of the exploitable value of the film or tape for a fixed amount of consideration or for a guaranteed minimum consideration which can reasonably be considered to be its fair market value."
