With the varying intrepretations, I would defer to a tax professional on this answer.
The IRS literature and documents clearly state if the property has transferred prior to December 1, 2009 you are eligible for the tax credit. You have to read ALL of the literature as there are exclusions clearly spelled out. I don't remember specifically reading what the IRS considers a closing, hence I would seek out specific tax advice from someone who would be prepared to back their interpretation for you if you take the credit.
Anyone can fill out the documents and any claim or filing can be made with the IRS for tax purposes, but their reviews can take up to two years to come back on a determination.....at that point you are dealing with penalties and interest. I don't know that an intrepretation has been made at this point.