The crux here is: what are "the purposes of this section" ?
Does it
(a) define the rules and conditions under which a taxpayer may claim a deduction on R&D expenditure
or
(b) define the obligations of the taxpayer with respect to anything that Sec 174 defines as R&D expenditure (i.e. you must report it as such, charge it to a capital account, claim an amortization deduction)
AFAIK, nothing the IRS or Congress has said thus far has clarified this.
Does it
(a) define the rules and conditions under which a taxpayer may claim a deduction on R&D expenditure
or
(b) define the obligations of the taxpayer with respect to anything that Sec 174 defines as R&D expenditure (i.e. you must report it as such, charge it to a capital account, claim an amortization deduction)
AFAIK, nothing the IRS or Congress has said thus far has clarified this.