Comment by ericpauley

You don't specify what is R&E, the statute does. It's specified in the next section, and section c(3):

" “specified research or experimental expenditures” means, with respect to any taxable year, research or experimental expenditures which are paid or incurred by the taxpayer during such taxable year in connection with the taxpayer’s trade or business."

and

"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."