Comment 2 for bug 386584

The milestone is created in a separate async request. The view that creates the release does not know the milestone was just created. When the release is created it can guess that a milestone that is less than 30 minutes old does not require a notification that it is closed.

We might consider the notification to be a device to deal with a bad design. If the milestone/release page clear stated that
    Bugs *cannot* be targeted to the milestone (!)
or
    Bugs *can* be targeted to the milestone (!)
We might not ever need to say that the milestone is active.