and when there are other well-respected tax experts (like the AICPA) who are saying that failure to file Form 3115 is a Circular 230 violation
To that point, you totally misconstrue what the AICPA has said. They're basically saying that the IRS has put practitioners into a position where, often, they simply can't comply. And because they can't comply, that would produce a 230 issue.
The small guy that owns a rental, who was told to maintain capital expenditure records...threw away his "repair" invoices from 15-years ago. This guy can't comply.
The AICPA recognizes that filing a 3115 with a $0 481 adjustment isn't compliance. This is exactly why they have asked for a prospective application of the Regulations.
If you think for a minute that your 3115's with a $0 adjustment will pass muster under these regulations, when we're talking about expenditures associated with a building, you're mistaken. Your 3115 filing is tantamount to not filing one at all. In fact, it is worse than that, since you are making an assertion, in violation of Circ 230, that is patently false.