qualified expenditure
(2) Qualified expenditure For purposes of this subsection, the term “qualified expenditure” means any amount which, but for an election under this subsection, would have been allowable as a deduction (determined without regard to section 291 ) for the taxable year in which paid or incurred under— (A) section 173 (relating to circulation expenditures), (B) section 174(a) (relating to research and experimental expenditures), (C) section 263(c) (relating to intangible drilling and development expenditures), (D) section 616(a) (relating to development expenditures), or (E) section 617(a) (relating to mining exploration expenditures).