According to FrankNY's post, dual boards with common control or common enclosure is where dual ID's may be issued. It reminded me of the crystal controlled era of dual IDs. One for the transmitter and one for the receiver (as pictured below on a GE Custom MVP). These old transceivers weren't modern transceivers in the sense of 1 board with TX and RX but each had their own boards which could be individually removed from the radio. Locally we actually have as set of MASTR II's, one 28 MHz and one 430 MHz, that had the receivers swapped (one receives 28 MHz and transmits 430 MHz an the other receives 430 MHz and transmits 28 MHz) to create a split site 10m repeater.
Now, according to the information available from AT.T, the 8R series to have a transceiver and a receiver for the crossband feature. However, the dual ID's were for transmitters and not a transmitter and receiver. We know it's the same transmitter for all services which would warrant a single ID for the actual transmitter.
The two deficiencies that stuck out to me on the dismissal letter were the FRS and MURS remarks. On UHF where AT.T. shot themselves in the foot was saying the radio has 23 GMRS channels.
In a channelized service, the FCC considers a channel to be a set RX and TX frequency. So what is the only way you can get 23 channels in a UHF Part 95 service? Have the 7 FRS only frequencies in there. Easiest way to correct this confusion, call them modes and not channels in your manual (this probably the exact reason why Motorola call's them modes on synthesized radio equipment) or reflash the radio for only 15 channels with the repeater inputs programmed in instead of a whole set of 8 simplex channels and offer a talk around option on said channels.
As far as the Part 95J comment goes, reading the rules we'll notice that they say 2W max. Not 2W on MURS or 2W VHF, 2W. I feel to obtain the certification the radio will have to be knocked down to 2W. Looking at other manufacturers equipment (Ritron) they make a VHF radio and then a completely separate radio with no more than 2W output for MURS.