OMB's legal rationale was crafted to respond to questions from the Government Accountability Office...
https://www.washingtonpost.com/business/economy/in-new-legal-memo-white-house-budget-office-defends-withholding-aid-to-ukraine/2019/12/11/0caa030e-1b95-11ea-826b-14ef38a0f45f_story.html
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