Cross-Jurisdictional Vouchering and Deluxe

Here's an interesting question: will the official legal opinion of HCD that cross-jurisdictional vouchering is not allowed effect the final outcome of Deluxe's vouchers with the BOE? On the one hand, it is only the most dubious vouchers that were rejected by the FTB in the first place and it is unlikely that Deluxe will be able to produce better documentation. On the other hand, if they do manage to come up with additional evidence, the fact that the vouchers didn't come from the local zone may make that moot.