h its installment method election. The Internal Revenue Service non-acquiesced to the Court's decision in AOD 1976-345. See also, Rev. Rul 90-38 and I.R.S. Tech. Adv. Mem. 200043010 (June 9, 2000). Similarly, in Standard Oil, the taxpayer made an election to write off intangible drilling costs (IDCs). Ther