Comment by grumple

I think the key words there are "For purposes of this section", which means if you're choosing to designate it as R&E for the purpose of taking the deduction, you can do that with all software related expenses. The core premise of this post seems nonsensical, you're not going to be taxed on revenue as though it was profit.

Not in any way qualified to provide tax advice, don't take the above as anything but idle chat.