When some of the 87,000 IRS enforcers carrying  AK-47s show up in jackboots at your client's door, they probably will have first reviewed this IRS training material:

https://www.irs.gov/pub/irs-utl/pst_c_366_01_01_01.pdf

and particularly the material on pages 14 et seq about the Renkemeyer decision from Tax Court.  As far as whether tax software should require an override for application of this situation, it gets back to "don't charge me for the cost of developing your special features that few other people will use."