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This piston comes to TDC two times.
One time it is the transition from the exhaust to the intake stroke, and both valves are slightly open.
The other time is the transition from the compression to the power stroke, and both valves are closed. You would have to turn the crank ~45 deg either direction to get a valve to start opening (actual numbers will vary depending on duration). This is approximately the position the original poster described.
I'm no expert, but I do not see anything wrong with this method. If there is, please explain it, as I would like to know too.
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