I spoke with a suitor who said effectively, I think the IRS is looking for a template like the LoR that they can attack and make it look as though Redeeming Lawful Money is bogus.

Most certainly that was Wserra's - Wesley SERRA - objective on Quatloos recently. I think that is quite possibly an objective but Congress says differently. If you contract with the Congress-created jurisdiction of the Fed, it would seem things get arbitrary fast. However if you stay out in the original cognizance of the Judiciary Act (1789 'saving to suitors') we find that the Memorandums are resorting to a term in context of the STRAWMAN REDEMPTION to attempt slurring LM redemption.

So maybe your gut is sensing the IRS desire more than the IRS ability to slur remedy?