High level feedback: you should spec out the opcodes as separate pieces of functionality as it sounds like OP_CD is really 3 or 4 opcodes in one (e.g., amounts to outputs, output addresses, something with fees).
One major drawback of your approach is that all transactions are twice as large as they might otherwise need to be for simple things like congestion control trees, since you have to repeat all of the output data twice.
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