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Disclosure Regs Lift Burden on Small Nonprofits, Colorado Groups Say

DEC. 6, 2019

Disclosure Regs Lift Burden on Small Nonprofits, Colorado Groups Say

DATED DEC. 6, 2019
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December 6, 2019

The Honorable Charles P. Rettig
Commissioner, Internal Revenue Service
U.S. Department of the Treasury
1111 Constitution Avenue, NW
Washington, DC 20224

RE: Comments on IRS Reg-102508-16: "Guidance Under Section 6033 Regarding the Reporting Requirements of Exempt Organizations"

Dear Commissioner Rettig:

Please accept these comments on behalf of our clients: Colorado Independent Action, Inc., a Colorado nonprofit corporation in good standing, and also Coloradans for Civil Liberties, Inc., a Colorado nonprofit corporation in good standing.

Both of these entities were established in 2015 to be tax exempt organizations under Section 501(c)(4) of the Internal Revenue Code. Forms 990-N were duly filed. Both of these entities are growing and now face the need to file a Form 990 with Schedule B. Our clients strongly support the proposal to eliminate the requirement to report names and addresses of contributors on Schedule B. Simply stated the elimination of the reporting requirement for these small entities without full time staff or accounting departments will decrease compliance costs.

The Internal Revenue Service is not tasked with campaign finance regulation. Rather, its job is to enforce the federal tax laws. Of course, if contribution information is needed in the course of a tax investigation, disclosure is appropriate. It is also important to note that other state and federal agencies have robust campaign finance regulatory systems.

In closing, please be aware that contributors are increasingly concerned about data security. These concerns are increasing with every media story about a security breaches, even of government databases.

Thank you for the opportunity to submit these comments.

Shayne M. Madsen
MADSEN & ASSOCIATES, P.C.
Denver, CO

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