401(b) transition period -- beginning date?

[Guest Alley]

Under the 410(B) transition rules, if a new member of a controlled group joins the controlled group Jan 1, 2002 and the plan is a calendar year plan, is there effectively a 2 year transition period? Can you take the position that the first day of the plan year after the company joined the controlled group is January 1, 2003? Or does that read the rule too agressively?