I don't know that you will find someone here that is knowledgable in the area you are looking at.

Here is a exerpt that I found with a quick google search that confirms this is very trick tax law.

In most cases, you can only deduct these expenses in the tax year in which you incur them. If you didn’t deduct those expenses at that time, the only way you can deduct them in later years is with smart patent accounting and with the consent of the IRS Commissioner. 

I have know idea what this clients does, how long they have been in business, how much risk is involved if the wrong decision is made.  But to me this sentence says that there can be high conseqences if this is not done correctly and is caught.

The immediate question that comes to mind with your description is:  Does it matter if the business is a going concern (operating) or not?  Then I would be looking for specifics as to what are patent costs, start-up costs, research and development costs and how to expenses of this client fit into those categories? 

Without a professional willing to mentor on this so that I could make sure of what I was doing, I would probably decline the client.