The question thereby presented is whether the IRS should be free to pick and choose which mandated statutes and regulations to apply, and to avoid other highly relevant ones, by ignoring or side stepping them, upon which countless disaster-victim taxpayers have properly relied, and will do so in the future, such that the impact of the decision below is to create a widespread deleterious result for many current and future taxpayers as to the questionable consistency and reliability of that agency's conduct, in effect constituting a rending of the very fabric of the nation's integrated tax system?

Whether the IRS should be free to pick and choose which mandated statutes and regulations to apply, and to avoid other highly relevant ones, by ignoring or side stepping them, upon which countless disaster-victim taxpayers have properly relied, and will do so in the future, such that the impact of the decision below is to create a widespread deleterious result for many current and future taxpayers as to the questionable consistency and reliability of that agency's conduct, in effect constituting a rending of the very fabric of the nation's integrated tax system?