Thank you for attaching US vs Rickman David.
That was an interesting read.

I think you are right about the IRS notices.
The notices seem to be the policy which the IRS agents follow.
The IRS gives public notice of its policies in those documents, and then its agents enforce those policies.
No tax payer can reasonably say that he didn't know what the rules were, since the policy rules are spelled out in the notices.

Bright blessings