A few final thoughts:

1) The 1099-R was only mentioned to possibly connect the coverage to a (former) employer.

2) For other clients, we've already used the PSO expansion (aka The Wally Bunker Bill), so that's a nice example of parity.

3) "The 2012 interpretation moves closer to parity, in that the self-employed person can include their own and/or a spouse's separate coverage ...". Not sure I totally agree with that sentence, since the 2012 Memo is only talking about Medicare, but I can appreciate the implication.

4) In conclusion ...

Using the SEHID parity theory, unless there's an Employer Subsidized Plan lurking somewhere, all TP/SP health insurance premiums are deductible, regardless of whose name is on the policy. 

So in the original example, I'm now deducting all $9000 in premiums.

If anyone has a different interpretation, please chime in. 

Thanks for all the help.