@PJC4
Your plan seems logical and well-reasoned.
I have noted, however, that the Safe Harbor provision of Rev. Proc. 2009-20 indicates that the executed statement in Appendix A must be completed and attached to your return.
EDIT: If you qualify to use Revenue Procedure 2009-20, as modified by Revenue Procedure 2011-58, and choose to follow the procedures in the guidance, first fill out Section C to determine the amount to enter on Section B, line 28. Skip lines 19 through 27. Section C of Form 4684 replaces Appendix A in Revenue Procedure 2009-20. You don't need to complete Appendix A.
