New Fed R&D expense amortization requirement

can't see how the irs could detect that even on audit if the r and d credit is not also claimed (on possibly a subset of r and d expenses) or if the biz has little or no income, and is a tech startup.

If it's a tech start up, I would think it's a must ask question.

If the PBA is in the right industry and there is no amortization on Form 4562, it would be easy. They could also query if there is a 6765 in 2021 and no 6765 in 2022.