I don't think it actually matters whether you use XHTML or plain HTML. The end goal here is to have low maintenance and quick development through a predictable rendering. You can get this from using xhtml or html, as long as you have validating code. I've even heard arguments that it's best to target quirks mode, because new versions of browsers don't change quirks mode, so maintenance is easy.
In the end, it all becomes tag soup, for good reason, because getting web app developers to write error-free html means asking them to write bug-free code. Validators are no help, because they only validate the initial page view. This is also why I've never seen the point in xhtml served as xml for anything beyond static sites. The level of arrogance a web apps developer would need to have to serve up their web app as xml is staggering.
