Could you please provide a code article that would override 334.10(3)? Basements would not be covered by (3) as they are not "other structures".
I run all my garage/shed etc runs inside the stud bay
But I've yet to see a shed/barn/unfinished garage/detached structure anywhere around here or other areas I've been where there is a "15 minute finish rating"
You can't pull one snippet of code out & ignore the rest of the code