This is pretty sound and all but two additional cards of MT-12s and T-80s?
The problem with 39th is that it has abysmal slot costs, not that it had too little stuff.
What you are proposing is that 39ya should have 28x 2800 meter anti-tank missile carriers, alongside all the T-80s and their kobras.
I believe 39ya should be more limited in its tanks since that's what makes 79ya different, It's built around their tanks and the BMPs, 39ya is differentiated by not having as many tanks an instead working with BTRs (with some support by the BMPs)