I agree with your interpretation of the language, but I'm never sure of the IRS's interpretation. I could not find any specific documentation on the topic, so I suggest you contact the IRS directly with the question.
You can call toll-free at 1-800-829-1040 or visit a Taxpayer Assistance Center Local IRS Office
If you don't get a satisfactory answer I agree with @DaveF1006 assessment to contact a tax attorney.
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