There is a good chance the ruling will change if enough people voice their concerns, the IRS is soliciting public feedback on the ruling, here it is in entirety:

http://www.irs.gov/pub/irs-drop/n-14-21.pdf?utm_source=3.31.2014+Tax+Alert&utm_campaign=3.31.14+Tax+Alert&utm_medium=email

there is a section that reads:

"Comments should be addressed to:

Internal Revenue Service Attn: CC:PA:LPD:PR (Notice 2014-21) Room 5203 P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044 or hand delivered Monday through Friday between the hours of 8 A.M. and 4 P.M. to: Courier’s Desk Internal Revenue Service Attn: CC:PA:LPD:PR (Notice 2014-21) 1111 Constitution Avenue, N.W. Washington, D.C. 20224

[email protected]. Taxpayers should include “Notice 2014-21” in the subject line. All comments submitted by the public will be available for public inspection and copying in their entirety."