Anyone with 529 to Roth rollovers?

There’s a grey area since the IRS hasn’t issued official guidance, so nobody actually can know the answer, but here’s my situation.

I split my daughters 529, which has been open for 17 years, into 3 accounts. One for me, the wifey and the daughter with about $150k in each. I split them so I can roll over a total of $105k tax free. $35k per person into those respective accounts.

The IRS text is hard to interpret. Technically, it reads that the account needs to be open for at least 15 years. If that’s the case, my daughter is even ineligible after 17 years since we closed the old account it was started in when we rolled it over to a Schwab 529. So, same beneficiary, same money, but technically new account.

However, if we assume, since IRS hasn’t said yay or nay yet, that since the original account is what fed the new account and new beneficiary accounts, we may rollover all three now.

It’s risky, so my question for those with more knowledge on the subject is this. If I roll over all three accounts next January, how likely am I to go under the radar without a request for more documentation, etc?

I know somebody has already done it and has a practical answer, but I haven’t found them. I’ve only found CFPs and CPAs that can’t answer this yet.

I wanted to post the IRS text, but I can’t add a pic to the post.