There is no ambiguity at all, no grey area, and no room for confusion. The regulation, repeatedly stated here, is crystal clear, even without the letter of interpretation or legal opinion.
Is there some confusion that a practical test for the flight instructor certificate, which is not a pilot certificate, counts for a flight review (no such thing as a "BFR")? None.
It may be "counted" for the hour of ground required in a flight review, in accordance with 61.56. That's it.
If an examiner is willing to sign off for completion of a flight review, then it's up to the examiner to take the responsibility to provide a specific endorsement stating that a flight review was conducted.
Of it's own accord, the practical test for the flight instructor certificate does not take the place of a flight review. There is nothing gray about it.
Is there some confusion that a practical test for the flight instructor certificate, which is not a pilot certificate, counts for a flight review (no such thing as a "BFR")? None.
It may be "counted" for the hour of ground required in a flight review, in accordance with 61.56. That's it.
If an examiner is willing to sign off for completion of a flight review, then it's up to the examiner to take the responsibility to provide a specific endorsement stating that a flight review was conducted.
Of it's own accord, the practical test for the flight instructor certificate does not take the place of a flight review. There is nothing gray about it.