Do you think explicitly singling out software development for unfavorable tax treatment while explicitly excluding oil and gas exploration from the same treatme

Do you think explicitly singling out software development for unfavorable tax treatment while explicitly excluding oil and gas exploration from the same treatment is "fair"? https://www.law.cornell.edu/uscode/text/26/174 https://www.law.cornell.edu/uscode/text/26/174 (c)(2) and (c)(3)