Comment from Obelisk Tech Systems Inc by James H. Poole on May 23, 2026
Obelisk Tech Systems Inc by James H. Poole on May 23, 2026OpposeBusiness
Summary: Obelisk Tech Systems Inc. opposes the proposed action, arguing that it contains twelve procedural and substantive defects regarding statutory compliance, regulatory review, and small business impact. The company requests that the IRS and Treasury withhold final guidance until these legal and procedural issues are corrected.
Comment of Obelisk Tech Systems Inc. on Docket IRS-2026-0067-0001 (Notice 2026-4). Obelisk identifies twelve procedural and substantive defects under the Internal Revenue Code (26 U.S.C.), Treasury Regulations (26 C.F.R.), the Administrative Procedure Act (5 U.S.C. §§ 551–559, 701–706), the Paperwork Reduction Act (44 U.S.C. §§ 3501–3521; 5 C.F.R. Part 1320), the Regulatory Flexibility Act (5 U.S.C. §§ 601–612), SBREFA (Pub. L. 104-121), the Congressional Review Act (5 U.S.C. §§ 801–808), the Taxpayer Bill of Rights (26 U.S.C. § 7803(a)(3)), and Executive Orders 12866, 13272, 13563, and 14094. Defects include failure to comply with APA § 553 notice-and-comment requirements (Mayo Foundation v. United States, 562 U.S. 44 (2011)); no documented OIRA centralized regulatory review under the Treasury-IRS framework; absence of a § 603 Initial Regulatory Flexibility Analysis; no PRA OMB Control Number disclosure; no Congressional Review Act submission status under U.S. Telecom Ass'n v. FCC; no SBREFA § 212 small entity compliance guide; no reasoned-explanation basis under State Farm, Encino Motorcars, West Virginia v. EPA, and Loper Bright; no Information Quality protocol; no SBA Office of Advocacy consultation under EO 13272; and no 26 U.S.C. § 7805(b) retroactivity analysis. Obelisk requests that the IRS and Treasury withhold final guidance until defects are cured. Full comment attached. — James H. Poole, Executive Chairman & CEO, Obelisk Tech Systems Inc. (CAGE: 9S0L8 | UEI: U34MSJ6A6413 | HUBZone-certified | ITAR-registered).