I saw my lawyer again today and, after restating that the CFE bill must be in the name of the person claiming an exemption from capital gains taxes, she emphasized the importance of having the CFE billing address exactly match the address of the property as given in the title documents. She said the CFE understood the importance of this and would readily cooperate in making any necessary changes.
! It's now Feb 2013. I just met with my lawyer and she said the same thing. I would just need my RFC, my FM2/3, and an electric bill and I could exempt all capital gains on the sale of my residence in Mexico. Bearing in mind that she's the one who decides this question, under Mexican Law, I consider the answer to be authoritative. The "limit" on value of the property that was spoken of earlier is 7.5 million, at this time, just about six million more than my condo is worth! so we are well within the limit of properties subject to the rule I mentioned. As related by my lawyer, the key is that Mexico be your tax home.
I know several people who sold properties in the past year and they used accountants who work with Notarios and for a smalll fee can get you all the facturas needed to make it a tax free transaction regardless of any other circumstance.