There is also the problem of the 2017 tax reform law. Up to 2017, you could choose to capitalize expenses that otherwise would have been deductible as schedule A miscellaneous itemized deductions subject to the 2% rule. After 2018, the 2% miscellaneous itemized deduction was eliminated. So there is a strong argument that capitalization is also no longer allowed (for 2018-2025, unless the law is extended.)