No, I’m suggesting that you don’t understand how decisions on what to work on are made in large business environments. This is true both for government agencies and large corporations. It’s why agility in business is something business schools study, and why many businesses die because they don’t react fast enough.

Look, the IRS has no obligation to pro-actively decide every conceivable case of state law interaction with federal law. It’s not enough that they be aware of all these special cases. Some one or group of people had to make a decision that these were more important to work on than all the other things they had already committed to work on before the states started doing this. Now I don’t know what their other priorities were at the time. So I can’t argue that they should have known this was or was not important enough to preempt other work. And neither can you. Large organizations, especially those that mostly work around a fixed calendar of work, can’t be expected to make every turn on a dime decision quickly and correctly.