Not only did Treasury/IRS not comply with the RFA or PRA. Not only did they delay an entire year in providing us with the Administrative record. But when they provided the administrative record what did we discover?
There is not a SINGLE document or email in it that supports their certifications that the regulations would not have a serious impact on a large number of businesses. Thus by definition they will lose the motion for summary judgement.
They have failed to disclose very harming documents and emails. We decided to bring this to the attention of the court.
Below, I provide you with the motion and related exhibits. This is the first time that you will see the pretty substantial paper trail I created over the last 2 years. I pretty much pinned them down.
To read the motion, see docket number 39 at www.courtlistener.com/docket/14527365/silver-v-internal-revenue-service/ or click here:
Motion to compel:
Exhibit 1: our attorney's meet and confer letter:
Exhibit 2: Government's letter in response.
Exhibit 3: The most damning documents that they did not include.