Yeah they could have released a form or granted everyone automatic safe harbor. Or going further back they could have worked out cost basis guidelines a decade ago and made them clear. Instead we get this compliance nightmare.
The thuggishness of this whole process really grinds my gears. They are changing the rules post facto and demanding a blank check to bill you in the past based on rules that didn't exist yet. The only way out is to follow vague and Byzantine instructions and produce "proof" that you were paying attention to the right guidelines at the right time.