Let's see if there is another way to approach this.
Jerry, you say that you bought ACS; lock, stock and barrel, as it were. Is there a method that you could have ACS as a subsidiary of USR? That way you could submit motors from ACS as ACS. The only issue with the paperwork then is the address. As we have seen, that is a non-issue from TRA/NAR's standpoint.
Just trying to think outside the box.
Bob