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There is also a lot of software that never ships because it’s intended to be internally used exclusively. 174 makes no distinction between internal/external products. I do not know if it makes a distinction between products and products-that-never-reach-market. I suspect it does not, since a core tenet of the regulation is that there must be some uncertainty of outcome in order to be research and development. Products that fail before reaching the market seem to fall in that zone of uncertainty and are likely deductible.

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