definiens: within the meaning of Section 7 121 of the Code ( or any similar provision of applic able state, local or foreign Law ) on or prior to the Clo sing Date, ( ii ) any intercompany transaction or exc ess loss account described in the Treasury Regulations promu lgated pursuant to Section 1502 of the Code ( or any similar provision of state, local or foreign Law ), ( iii ) an y installment sale or open transaction disposition made on or prior to the Closing Date, ( iv ) any prepaid amount received or deferred revenue accrued on or prior to the Closing Date, ( v ) any use of an improper method of accounting for a taxable period ending on or prior to the Closing Date, ( vi ) election by any of the Acquired Companies under Code § 108(i ), ( vii ) any adjustments pursuant to Section 481(a ) of the Code or any simil ar provision of Law as a result of a change in meth od of accounting with respect to any period ending on or prior to the Closing