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 th