I do love the 8275.  That gives me a lot of peace of mind amidst uncertainty.

I don't know that the married couple and community property rules would help if the IRS deems this disparate ownership down the road.  Even if they share ownership and a personal income tax return, the case could be made that half of their collective ownership received a tax benefit (and possibly a basis impact? TBD) that the other half didn't.

Good call extending.  If guidance comes out saying this isn't allowed after all, even if it's an irrevocable election, you'd have more room to say "oops, mea culpa" and fix it.