The International Organization for Standardization (ISO) developed ISO 9000, a series of international standards for quality management systems. The ISO 9000 series of standards is comprised of several specific requirements intended to ensure a quality process in providing services or products to an organization's customers. To obtain certification, an organization may incur internal and external costs to assess its current quality processes, create a quality manual, train its employees, and implement the new quality system. In addition, the organization incurs costs to obtain formal certification from an independent auditor that its quality management system conforms to a specific ISO 9000 standard. This certification generally lasts from two to four years. Are costs incurred by a taxpayer to obtain, maintain, and renew ISO 9000 certification deductible as ordinary and necessary business expenses under 162, or must they, be capitalized under 263 or 263A? Explain with references to primary sources.