@RCNorth -
The challenge I suspect you are going to have is that while the IRS permts you to apply the "facts and circumstances" to the equation, I do not see where it permits you to dismiss the 730 days of residency in a 5 year period and rest solely on the facts and circumstances. The IRS states "the most important factor is where you spend the most time" . The fact that you only spend 5 months of year in what you claim to be your 'main residence' is the challenge to the IRS requirements..
This article also spells out the challenges. It is not cut and dry.
https://www.taxaudit.com/tax-audit-blog/how-does-the-irs-define-primary-residence
my recommndation, and those of others on this thread, is to seek local tax advice from a professional. Debating with us won't satisfy the IRS if it comes to that. And we are anonymous to you.
For the amount of money at risk, and the "fire" you are playing with, please do yourself a favor and and spend a few bucks with a local tax attorney that you can trust. It will be money well spent.
