Mr. Veretsky.

Mr.

Chief Justice, and may it please the court.

The court should either affirm or dig.

The government came to this court with a dispute about when it must meet its burden to prove that a lawful permanent resident may be treated as seeking an admission to the United States, at the border or before an IJ.

Only now, in its merits reply and here today, does the government say the case is about the burden of proof, a question that it forfeited before the Second Circuit and conceded in its cert reply was not contested.

The INA's text and structure, plus historical practice, make clear that an officer must decide at the border whether an LPR is seeking an admission.

Can you address those consequences?