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> I bet they were classified as R&D for accounting purposes.

It's not just that. Section 174 now explicitly calls out Software as always being an R&D expense:

> (3) Software development

> For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure.

https://www.law.cornell.edu/uscode/text/26/174



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