Yup, those were the results.  No penalty but ProSeries did calculate it with me and it is still there.  I looked carefully to see if I overrode anything and used the review tool to look for overrides, but no.

Thanks for trying!  I hope the explanation letter sheds some light.  I hope they send it to me!  They are elated about the refunds and not terribly interested in my looking into it.

The 3853 instructions are very difficult; this whole rule is difficult to decipher when you don't need it very much.  Yet, I really could not find a reason for no penalty.  And that estimator tool, which is from the FTB, calculates the penalty.