Equalizer very good post. I would agree first off that most likely 99% of all homeowners who do pay Mello Roos of primary residences do indeed deduct them. However when I am asked are they deductible I routinely answer just like I did in this post. First sentence,

“consult the tax code”.

which is what you have done which is a good job. Still though, my CPA plays it very close to the vest with regards to taxes, probably closer then it needs to be and my answer mirrors his guidance on that.

Your answer is more technically correct, my very first sentence not withstanding.