Depends on the state. Georgia, where Carter lives, is silent on the issue so it should count. Some state explicitly allow counting them, some states explicitly forbid counting. Some states are silent on the issue.
I use 3M 850 tape for all my bellows. It's very strong, blocks light, and really flexible, the adhesive stands up to cold and heat without changes. Very thin. The bellows on my Wista 45 has been patched with this stuff for probably five years now and it's still perfect and it's on at least three other bellows.