shift is rational and, therefore, not arbitrary and capricious. Id. (internal citations omitted). “[Tjhis is not a difficult standard to meet.” Id. We have recognized that after the Supreme Court’s decision in United States v. Mead Corp., 533 U.S. 218, 121 S.Ct. 2164, 150 L.Ed.2d 292 (2001), the level of deference owed to an informal agency interpretation is “freighted with uncertainty.” Doe v. Leavitt, 552 F.3d 75, 79 (1st Cir. 2009) (noting that Mead “does not clarify the circumstance in which Congress should be deemed to have intended an informal agency interpretation to carry the force of law and thus, attract Chevron deference”). Arguably, the AAO’s unpublished decision may lack force and as such, Chevron deference could be inappropriate. See Mead, 533 U.S. at 221, 121 S.Ct. 2164 (<HOLDING>); Christensen v. Harris County, 529 U.S. 576,
holding that there is no indication in the legislative history or the language of  6330 that congress intended for taxpayers to have the right to subpoena witnesses or documents at a collection due process hearing holding that a tariff classification does not warrant judicial deference under chevron because there was no indication that congress intended such a ruling to carry the force of law holding the 2008 fcc ruling had the force of law holding that there was no question that the full and fair opportunity element was met where there was no indication that such an opportunity was unavailable holding that bankruptcy courts order was final where is was labeled as a final judgment and was clearly intended to serve as denial of relief sought the order determined the substantive rights at issue there was no indication in the record that the court intended to take further action and no party argued that any further action by the court was to occur