In a stunning victory that suprised every single expert, the judge's ruling, issued Christmas eve, is simply unprecedented. The Banking industry failed to get around the Anti Injuction Act in the Florida Bankers case. The insurance company failed as well in the CIC case.
And we did it!!! On a shoe string budget. Not only did we do it, but the ruling is so one sided that even I was shocked. The government "fundementally miscontrues" our case - the judge said.
And I knew it all along. How could this have happened? A wide variety of explanations can be given. (i) The government and all the experts simply do not have any idea what the RFA and PRA are. No one does, as it has never been used. (ii) The government and experts all deal with tax disputes, not administrative law, which as the judge correctly identified, is the essence of this case. This is not a tax case. This is an administrative law case. (iii) The government and experts completely misunderstood the Anti-Injunction Act, or why it does not apply in the case.
This ruling is a watershed event in administrative law, across all federal agencies! Now on to the merits. Mark my words - a walk in the park compared to this motion.
To read the judge's ruling, click here.https://drive.google.com/file/d/1wxNC3f0uB4XMqZVrPps_pH8KmwciSCG8/view?usp=sharing