I am waiting to see how they deal with MFJ returns with community income and unemployment more than $10,200 -- and how they figure out if the taxpayers lived in a community-property state, anyway.  

I think what's more likely is that IRS will send the taxpayer a "reverse CP 2000" -- proposing to give them the exclusion but asking them to sign off on it.  Clients will call us, we'll do all the work for free because, of course, it's our fault they got the notice.