no, like described in my initial post lsof does not show anything in
this case. also there is no reason to assume that any process (other
than umount) is opening a file in /mnt if you use the commands i've
posted. it is reproducible with the kernel version i've posted and it
only happens if umount is called on /mnt/issue (e.g. by umount /mnt/*).

however, it looks like newer kernel versions do not have this issue. so
it seems like someone fixed this issue....

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https://bugs.launchpad.net/bugs/1358310

Title:
  using umount with bash wildcard ends in "device is busy" for mount of
  parent directory

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