The legality of the alleged actions by the Obama administration would almost certainly be in question.
“Federal laws protect the confidentiality of tax returns and tax information. According to 26 § U.S.C. 6103, it is unlawful for an employee of the United States or a State to “disclose any return or return information obtained by him in any manner in connection with his service … The law allows for tax information to be used for the limited purpose of determining ACA subsidy eligibility. It does not, however, permit CMS to market ACA subsidies to taxpayers who have already rejected ObamaCare,” CoA states in the FOIA request.