As I have told senior Treasury/IRS officials since August 2018 when the proposed regulations came out, I have anticipated their defenses and will get around them.
To see our opposition to the motion, and to understand our arguments on standing and the Anti Injunction Act, see below.
https://drive.google.com/file/d/1z1r-tqp8YHfP4IZufJN56cDygZ4l5gwP/view?usp=sharing