Jose wrote:
Ifind the FSDO doesn't find it too amusing when you try to play lawyer
with them and find odd loopholes in the law.

It's what their lawyers do with you if they get the urge.

But there isn't much you can do to prevent that. The only thing that
will prevent that is to convince the FAA Chief Council to issue a
formal ruling. Short of that, the FAA can (and does ) change its mind
during enforcement.

-Robert