Like pretty much any person/entity that has a California tax ID in the State of California is by default an agency (franchisee and customer) of the FTB when it comes to tax collection. If there is a sharing of civil awards with the State, that is probably why they are made to appear to be a government organization (the State gets a share and the FTB is the peering collection agency). Fake government posing as government getting government help with the appearance only because of a profit-sharing plan with the State? Hmm that might explain a lot of things.
[Dolores Umbridge, Senior Undersecretary, Ministry of Magic - Dolores Umbridge is the only person known to have held the title, serving under Cornelius Fudge, Rufus Scrimgeour, as well as then Pius Thicknesse, until she was arrested and imprisoned in Azkaban for her crimes against Muggle-borns in 1998.]
When the non-law suggestion diverges from the law, I more and more see the suggestion as bait (counteroffer) into "Administrative La La Land"--"No, thank you" being words used to decline being teleported into Oz. So the legal positivist (lawyer-wizard-psychologist) might be inclined to lie (or, alternatively, to suggest). Someone's acceptance of such an offer (counteroffer or suggestion) to be transported to Oz would might make non-law as if "positive law"?
I'm reminded at this time of being told about houses I was in the process of purchasing that "BTW, the Historical Society won't let you do this or that." Although I would for the most part tend to avoid harming the historic qualities of a property or neighborhood, I smirked inwardly at the front office legislation. They are presuming you're going to delegate authority to one private tribunal or another. In the U.S.A. the realtors are more often than not used as pushers for all kinds of nonsense regarding "what you can" or "what you can't do" (legislation by rumor). Imagine legal-positivist suggestion and rumors from your neighborhood realtor being taken as "covenants that run with land" unless you specifically decline? Oh my.
Refusal for cause and right of avoidance ..so very important. It might be worthwhile having a template letter for asking any person if they are a bona-fide government official and showing them the law and penalties for falsely impersonating a government official...giving them 3 to 15 to 30 days to show proof. (Much like a Writ of Quo Warranto)
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