Taxpayer is a restaurant that sells gift cards. Historically has treated un-redeemed gift cards as deferred revenue for book and tax purposes. Assume pre-TCJA method was correct. Taxpayer does not have an AFS.
Post TCJA - there is a cut-off method permitted under Rev Proc 2019-37 (I think). Would this:
1. Apply to a non-AFS taxpayer?
2. If so - would the taxpayer bifurcate between advance payments received pre-2017 and post-2017 (and so only look at post-2017 payments in light of the TCJA rules)?
3. Does the Rev Proc allow the taxpayer to continue to use a deferral method for the post-2017 sales, even without filing a 3115?