Do I have this right? AICPA has standing to sue after all, but they still lost because IRS does indeed have authority to establish the AFSP Record of Completion?
D.C. Circuit upholds IRS unenrolled tax preparer program
" the AICPA’s members have both constitutional and statutory standing because they employ unenrolled preparers and the Program increases the supervisory burdens on AICPA members with respect to those employees."
Just because they voluntarily employ someone who voluntarily participates in AFSP, that gives them standing to argue that it's unlawful? I don't get it. If it's a problem, simply don't hire any AFSP completers, many of whom have no interest in working for CPAs anyway.