The difference appears to be that Code Section 197 is specifically for certain intangibles. Amortization of goodwill and certain other intangibles. The Safe Harbor De minimis refers to tangible business, otherwise depreciable items, under $2,500 being expensed.
Section 197(a) provides that a taxpayer is entitled to an amortization deduction with respect to any amortizable section 197 intangible. Here is a link for additional information.
The de minimis safe harbor is an administrative convenience that generally allows you to elect to deduct small-dollar expenditures for the acquisition or production of property that otherwise must be capitalized under the general rules. Click HERE for more information.
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