Not sure what you’re implying, but legal interpretations are not written in a vacuum. The people who are responsible for the policy provide input (if they don’t write the first draft of the interp in its entirety) to the attorneys who prepare the letter for the chief counsel’s signature.
Either way, I get that you and Steven disagree with the interp. Heck, in principle I do too, but that doesn’t change what was written. Like I said, do what you choose to do at your own risk; 999 times out of 1,000 you’ll be fine. As an instructor, I don’t teach or recommend procedures to others that I can’t trace back to statute, regulation, policy, or guidance.
Ironically, Leidos files just about 50% of my VFR flights using an IFR flight plan. Of course, I’m based inside the DC FRZ, so it’s a required procedure and I don’t have a choice if I want to take off.