Its a TriStar? Sh*t, I thought it was a DC10!
Thanks for the references. FARs and JARs are nearly identical.
I'm with you on the gear stuff. I can believe that ZFM is limited by the in-flight condition but I can't see any direct link between the loads you quoted and the MZFM limit.
JAR/FAR 25.301(b), which follows the para you quoted and describes how load limits should be etablished for the whole of Subpart C, says that load intensities should 'closely represent actual conditions' which implies, to me, a normal fuel load. JAR/FAR 25.321(3), which deals specifically with flight loads, requires, as you say, any practical distribution of disposable load. Disposable load is traffic load and fuel.
I appreciate your effort, but I just don't see a clear link to MZFM unless you start off by assuming these loads affect the same part of the structure as MZFM and argue a posteriori .