charitable purpose but, instead, served to promote "the private interests of home sellers and other private parties" and, consequently, (ii) the payments made by home sellers to the organization would not qualify as "charitable contributions" for which the seller could claim a tax deduction. And in November 2005, the Department of Justice filed suit in Chicago on behalf of the IRS, seeking an injunction against an Illinois-based seller-funded down-payment program. The injunction sought to bar that program from "falsely advising" home sellers that they could claim their payments to the program as charitable-contribution tax deductions. The IRS made its findings applicable to all seller-funded down-payment assistance programs when it issued a revenue ruling in May 2006. That ruling, Revenue Ruling 2006–27, contrasted the tax treatment of seller-funded programs with the treatment accorded to other types of down-payment assistance. Seller-funded programs, the ruling stated, were "not operated exclusively for charitable purposes". Furthermore, payments made by the seller to the organizations were to be treated not as charitable contributions, but either as rebates to the home buyer or as reductions in the sales price of the home. Shortly after the revenue ruling was issued, Nehemiah published an open letter from its president, in which it noted its opposition to the ruling but added that the ruling did not prevent the Nehemiah Program from continuing its operations. The letter did note, however, that Nehemiah might have to pay "appropriate business taxes on the revenue generated by its downpayment assistance program". HUD tried again to implement a regulatory prohibition of seller-funded down payments when it re-proposed, in May 2007, its failed 1999 proposal. There were some 15,000 comments from the public, the majority of which were brief statements of opposition written "in a standard similar format and wording". While the period for public comment was still open, the Committee on Financial Services held a hearing on down payment assistance, a primary topic at which was the HUD proposal. Nehemiah's president gave testimony at this hearing, saying "mend it, don't end it" and, in a written statement, adding that the proposal "makes no sense as rational behavior or measured action". In October 2007, HUD pronounced its proposed change as "final", meaning that it now would be implemented, with an effective date of October 31, 2007. However, Nehemiah sued HUD in a federal district court, citing violations of the Administrative Procedure Act. In particular, Nehemiah alleged