You'd be surprised how many people follow politics as if it were sports. The politic tactics surrounding the story are an angle that their readers are interested in, and they have real consequences as well. I think you'd have to consider all their coverage of the story as a whole to analyze their slant (which is Democratic, of course.)
No, I don't think that would be an appropriate headline in that case. But that is somewhat of a red herring/straw man since I am sincerely doubtful that was the first headline they put up. More likely that came a day or two after the story broke. And in that case, it would be appropriate.
That's a headline from Sunday May 12th, which I believe is the first story on it in the Times. The information first came to light at a press conference by Lois Lerner on May 10th and I don't see another NY Times article sandwiched between the dates. The headline did not go unremarked in conservative media[1].
There is no doubt in my mind which team the NY Times is batting for.
