(A) Tangible personal property. (B) Computer software (as defined in section 167(f)(1)(B)). (C) Property described in section 168(f)(3). (D) Property described in section 168(f)(4). (E) Food and beverages which are prepared by the taxpayer but not primarily for consumption at property owned by the taxpayer. (e) Special rules For purposes of this section— (1) Controlled group All members of the same controlled group of corporations (within the meaning of section 52(a)) and all persons under common control (within the meaning of section 52(b)) shall be treated as 1 person for purposes of this section. (2) Predecessor Any reference in this section to an employer shall include a reference to any predecessor of such employer. (3) Certain qualified progress expenditures rules made applicable Rules similar to the rules of subsections (c)(4) and (d) of section 46 (as in effect on the day before the enactment of the Revenue Reconciliation Act of 1990) shall apply for purposes of this section. (f) Election To apply credit against payroll taxes (1) In general At the election of the eligible employer, section 3111(f) shall apply to the payroll tax credit portion of the credit otherwise determined under subsection (a) for the taxable year and such portion shall not be treated (other than for purposes of section 50(c)) as a credit determined under subsection (a). (2) Payroll tax credit portion For purposes of this subsection, the payroll tax credit portion of the credit determined under subsection (a) with respect to any qualified small business for any taxable year is the least of— (A) the amount specified in the election made under this subsection, (B) the credit determined under subsection (a) for the taxable year (determined before the application of this subsection), or (C) in the case of an eligible employer other than a partnership or S corporation, the amount of the business credit carryforward under section 39 carried from the taxable year (determined before the application of this subsection to the taxable year).