Jim Gadwood's comments from his presentation at the Federal Bar Association's annual conference were included in coverage by Law360. Clients traditionally have had two options for overturning a tax regulation: violate it and wait for the government to prosecute them or follow it and pay before seeking a refund, Gadwood said. Each option has its drawbacks — break the law or pay — so pre-enforcement challenge to a regulation may be an attractive third option, he said. However, the approach is "cloudy with a chance of success," Gadwood said, because standing and the Anti-Injunction Act are two big obstacles to bringing a suit, as demonstrated by two recent cases.