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CREW Requests Guidance on Political Activities of Exempt Organizations

APR. 9, 2013

CREW Requests Guidance on Political Activities of Exempt Organizations

DATED APR. 9, 2013
DOCUMENT ATTRIBUTES
  • Authors
    Weismann, Anne L.
    Sloan, Melanie
  • Institutional Authors
    Citizens for Responsibility and Ethics in Washington
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2013-8483
  • Tax Analysts Electronic Citation
    2013 TNT 69-16
BEFORE THE INTERNAL REVENUE SERVICE U.S. DEPARTMENT OF THE TREASURY Petition For Rulemaking On Political Activities by Section 501(c)(4) Organizations

1. Citizens for Responsibility and Ethics in Washington ("CREW") respectfully submits this petition for rulemaking seeking a revision to existing regulations governing the standards for granting tax exempt status to certain organizations under 26 U.S.C. § 501(c)(4). Current Internal Revenue Service ("IRS") regulations contravene the Internal Revenue Code (the "Code") by authorizing organizations that engage in political activities to operate as § 501(c)(4) organizations, notwithstanding the statutory requirement they be operated exclusively for the promotion of social welfare.

2. This petition incorporates by reference the rulemaking petition submitted by Democracy 21 and the Campaign Legal Center on July 27, 2011, and supplemented by letter dated March 22, 2012. CREW submits this additional rulemaking petition to update the IRS on the impact of the political activities in which § 501(c)(4) organizations were engaged during the most recent election cycle, which provides additional and compelling evidence of the need for the IRS to revise its regulations.

3. Petitioner CREW is a non-profit, non-partisan corporation organized under section 501(c)(3) of the Code. CREW is committed to protecting the rights of citizens to be informed about the activities of government officials, ensuring the integrity of government officials, and protecting the integrity of our political system against corruption. CREW works to advance reforms in the areas of campaign finance, lobbying, ethics, and transparency. Further, CREW seeks to ensure campaign finance laws are properly interpreted, enforced, and implemented. To advance its mission, CREW uses a combination of research, litigation, advocacy, and public education to disseminate information to the public about public officials and their actions. Part of CREW's work includes exposing the special interests that have influenced our elections by secretly pouring vast amounts of money into the political system, often shielding the sources of money through the use of tax-exempt organizations operating under § 501(c)(4) of the Code.

 

Statutory and Regulatory Background

 

 

4. In 1913, Congress for the first time provided a tax exemption for "any civic league or organization not organized for profit, but operated exclusively for the promotion of social welfare." Revenue Act of 1913, ch. 16, § II(G)(a), 39 Stat. 172. In the repeated recodifications of this provision over the years, Congress consistently limited the tax exemption to organizations "operated exclusively" for the promotion of social welfare.

5. The current version of the Code provides a tax exemption for:

 

Civil leagues or organizations not organized for profit but operated exclusively for the promotion of social welfare, or local associations of employees, the membership of which is limited to the employees of a designated person or persons in a particular municipality, and the net earnings of which are devoted exclusively to charitable, educational, or recreational purposes.

 

26 U.S.C. § 501(c)(4)(A) (emphasis added). Organizations subject to this provision are known as "§ 501(c)(4) organizations."

6. Prior to 1959, Treasury and IRS regulations promulgated to implement the statute limited the tax exemption for § 501(c)(4) organizations to those "operated exclusively for purposes beneficial to the community as a whole." See, e.g., Treas. Reg. 65, Art. 519, T.D. 3640, 26 Treas. Dec. Int. Rev. 745, 897 (1924); Treas. Reg. 111, § 29.101(8)-1 (1943); Treas. Reg. § 39.101(8)-1 (1954).

7. After Congress recodified the statute in 1954, Internal Revenue Act of 1954, Pub. L. No. 83-591, ch. 736, 68A Stat. 163, the IRS promulgated new regulations implementing the statutory provision that provides a tax exemption for civic leagues or organizations operated exclusively for the promotion of social welfare. T.D. 6391, 1959-2 C.B. 139. Those regulations are identical in substance to the current regulation, under which a "civil league or organization may be exempt as an organization described in § 501(c)(4) if -- (i) It is not organized for profit; and (ii) It is operated exclusively for the promotion of social welfare." Treas. Reg. § 1.501(c)(4)-1(a)(1).

8. But while this regulation mirrors the statutory language, IRS regulations defining the term "promotion of social welfare" depart radically from the statute. Specifically,

 

[a]n organization is operated exclusively for the promotion of social welfare if it is primarily engaged in promoting in some way the common good and general welfare of the people of the community. An organization embraced within this section is one which is operated primarily for the purpose of bringing about civic betterments and social improvements.

 

Treas. Reg. § 1.501(c)(4)-1(a)(2)(i) (emphasis added). At the same time, Treasury regulations exclude from the definition of the "promotion of social welfare" "direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office." Treas. Reg. § 1.501(c)(4)-1(a)(2)(ii).

9. IRS policy directives implementing these provisions provide that an organization may carry on lawful political activities and still be entitled to tax-exempt status under § 501(c)(4) as long as the organization is primarily engaged in activities that promote social welfare. Rev. Rul. 81-95, 1981-1 C.B. 332. The IRS has not further defined the "primary activity" standard its regulations establish. Instead, in a revenue ruling, the IRS has stated only that all facts and circumstances are taken into account in determining the "primary activity" of a § 501(c)(4) organization. Rev. Rul. 68-45, 1968-1 C.B. 259.

10. Groups seeking or claiming § 501(c)(4) status have interpreted the "primary activity" requirement to mean they can spend up to 49 percent of their total expenditures in a tax year on political campaign activities without such campaign activities constituting the "primary activity" of the organization. At the same time, such groups -- like all groups organized under § 501(c)(4) -- are not required to disclose publicly the names of their donors. 26 U.S.C. §§ 6104(b), (d)(3).

11. The discrepancy between the "operated exclusively" standard of the statute and the "primarily engaged" language of the regulations was a cause of controversy at the IRS both during the drafting of the regulations and for two decades after they were promulgated in 1959. A 1978 internal memorandum attached to a General Counsel Memorandum ("G.C.M.") describes the files underlying the 1959 regulatory drafting process as "addressed to the fact that the statute says 'exclusively' and the Regulations say 'primarily.'" G.C.M. 38215, 1979 G.C.M. LEXIS 269, at *25. While these files addressed the discrepancy in the context of section 501(c)(3), the § 501(c)(4) regulations "were very significantly shaped by reference to, and in conjunction with, decisions made with respect to the section 501(c)(3) Regulations." Id. at *26.

12. The controversy continued immediately after the IRS promulgated the § 501(c)(4) regulations. In 1962, the IRS's chief counsel twice rejected recommendations to deny tax-exempt status under § 501(c)(4) to organizations engaged in some amount of non-social welfare activity. In one case, the organization was conducting political activity, and although the chief counsel noted the difference between the statute and the regulations, he construed the regulations to "in effect deny exemption only to organizations that are primarily engaged in" political activity. G.C.M. 32394, 1962 WL 14007. In the other case, the chief counsel similarly noted the discrepancy and concluded, "a policy decision as to whether the language of the statute or the regulations controls should be reached before any significant ruling position is adopted." G.C.M. 32395, 1962 WL 14008; see also G.C.M. 38215, 1979 G.C.M. LEXIS 269, at *3-4, 22. Although the IRS initiated what it referred to as a "regulations project" in 1963, presumably to address this issue, it took no further action on it. Id.

13. The IRS again revisited this "perennially troublesome question" in the 1970s. Id. at *20. In response to a request for a revenue ruling, a proposed G.C.M. drafted in 1976 suggested a decision should be made as to whether the language of the statute or the regulations controls. Id. at *23. In response, the Exempt Organizations Division studied the issue and concluded the IRS should recommend to the Department of the Treasury that "the 'primary activities' test be eliminated from the Regulations and an 'exclusive' test tolerating no more than an insubstantial amount of activities not in promotion of the social welfare be substituted." Id. at *24-25. Nevertheless, after considering the issue for the next several years, senior officials rejected the recommendation and decided not to initiate a regulations project, leaving the regulations in conflict with the Code. Id. at *4, 17-18, 25. The IRS declined to reconcile its regulations with § 501(c)(4) of the Code despite the acknowledgment by one official that "it has long been recognized [the regulations] are an unduly broad interpretation of the statute." Id. at *20.

 

Factual Background

 

 

14. By permitting a § 501(c)(4) organization to engage in political activities as long as those activities are not the "primary purpose" of the organization, the IRS regulations have created a huge loophole in the statutory scheme. This loophole has enabled individuals and groups seeking to covertly influence elections to funnel large amounts of money through § 501(c)(4) organizations without having their identities and roles exposed.

15. According to the Center for Responsive Politics, spending by § 501(c)(4) organizations in the 2012 election cycle, based on what the groups reported to the Federal Election Commission ("FEC"), totaled a staggering $254,293,825.1 This amount was spent by 139 groups organized under § 501(c)(4), id., and includes $131.3 million spent on congressional races.2 Political spending by § 501(c)(4) organizations was roughly equal to the outside spending by political parties during the 2012 election cycle, and that spending was topped only by Super PACs, which spent a total of $623 million. Id.

16. Section 501(c)(4) organization spending increased significantly from the 2010 election cycle. Information compiled by the Center for Responsive Politics indicated in the 2010 congressional elections, 39 groups organized under § 501(c)(4) spent $100,000 or more on political activities, for a combined total of more than $78 million.3

17. Four § 501(c)(4) organizations dominated outside spending in the 2012 election cycle: Crossroads GPS, founded by Karl Rove; Americans for Prosperity, founded by the Koch brothers; Americans for Tax Reform, founded by Grover Norquist; and the American Future Fund, founded by Nick Ryan, a longtime political advisor to former Republican Iowa Congressman Jim Nussle. Together with the U.S. Chamber of Commerce, a § 501(c)(6) organization, these groups spent $295 million on political activities since the beginning of 2011. Paul Blumenthal, Dark Money' In 2012 Election Tops $400 Million, 10 Candidates Outspent By Groups With Undisclosed Donors. Huffington Post, Nov. 2, 2012. Overall, the amount of "dark" money spent by groups not required to disclose their donors in the 2012 elections was more than twice what was spent in the 2010 election cycle. Id.

18. According to the Center for Responsive Politics, in the 2012 election cycle, Crossroads GPS spent $70,968,744 in independent expenditures;4 Americans for Prosperity spent $33,542,051 in independent expenditures;5 American Future Fund spent $24,499,533 in independent expenditures;6 and Americans for Tax Reform spent $15,794,552 in independent expenditures.7

19. In the 2012 election cycle, § 501(c)(4) organizations had a huge impact on a number of Senate and House races. For example, in the Virginia Senate race, § 501(c)(4) organizations spent a total of $14,721,626, which represented 30.69 percent of all outside spending.8 Crossroads GPS led the pack, spending $10,559,237 on the 2012 Virginia senatorial election, followed by the League of Conservation Voters at $2,027,693. Id.

20. Similarly, in the 2012 Nevada Senate race, § 501(c)(4) organizations spent a total of $12,146,980, which represented 46.49 percent of all outside spending.9 Again, Crossroads GPS led the pack, spending a total of $6,654,542, followed by the Patriot Majority USA at $3,464,537, and the American Future Fund at $1,299,599. Id.

21. In the 2012 Wisconsin senatorial race, § 501(c)(4) organizations spent a total of $9,221,892, which represented 22.02 percent of all outside spending.10 Crossroads GPS spent the most, at $4,717,099, followed by Americans for Prosperity at $1,473,349. Id.

22. In the 2012 Ohio Senate race, spending by § 501(c)(4) organizations totaled $8,119,744, which represented 22.36 percent of all outside spending.11 As in the other races, Crossroads GPS spent the most at $6,363,705. Id.

23. House races also saw significant spending by § 501(c)(4) organizations. For example, in the Ohio 6th Congressional District race, § 501(c)(4) organizations spent a total of $3,160,601, or 43.28 percent of all outside spending.12 Americans for Tax Reform led the way, spending a total of $3,125,327. Id. In the Pennsylvania 12th Congressional District race, § 501(c)(4) organizations spent $2,999,409, or 28.92 percent of all outside spending.13 Again, Americans for Tax Reform spent the most at $2,517,329. Id. In the Colorado 3rd Congressional District race, spending by § 501(c)(4) organizations totaled $1,616,543, a whopping 61.01 percent of all outside spending.14 Americans for Tax Reform led, spending $1,575,152. Id. Further, in the New York 25th Congressional District race, § 501(c)(4) organizations spent $1,245,115, or 51.03 percent of all outside spending.15 The leader was Crossroads GPS, which spent $1,227,057. Id.

24. Without question, § 501(c)(4) organizations had a significant and direct influence on the outcome of at least some of the 2012 races. For example, spending by the § 501(c)(4) group American Action Network ("AAN") in the 13th Congressional District of Illinois race in 2012 likely resulted in the defeat of Democratic candidate Dr. David Gill. AAN was able to have this kind of political influence as a direct result of its ability to exploit the loophole created by the IRS's "primary activity" regulation, which allowed it to pour vast amounts of dark money into the race.

25. AAN first sought approval by the IRS to be recognized as a § 501(c)(4) organization in February 2010.16 In its application, AAN represented that while its primary focus would be on lobbying and educational efforts designed to promote social welfare, it also would engage in political campaign intervention on an ongoing basis.17 AAN characterized this political work as a minor portion of its activities, stating it expected to spend less than 20 percent of its resources on political activities. Id. at 5, 8-9.

26. On April 3, 2010, the IRS granted AAN's application for § 501(c)(4) status.18 Within days of receiving this approval, AAN announced publicly the group hoped to be active in eight to ten Senate races and 25 House races in 2010, for which it raised $25 million. Peter H. Stone, Party Allies Raising Millions, National Journal, Apr. 16, 2010. Reports AAN submitted to the FEC reveal the group spent $18,945,602 on political activities during the 2010 election cycle.19 This amount included more than $4 million on independent expenditures expressly advocating the election or defeat of candidates for public office, and $14.9 million spent on electioneering communications -- advertisements broadcast close to an election that mention a candidate by name. Id.

27. In the 2012 election cycle, AAN again engaged in substantial political activity. As part of that activity, AAN targeted the 13th Congressional District race in Illinois, where Dr. Gill was running against Republican candidate Rodney Davis. According to reports AAN submitted to the FEC, the group spent $1,482,562 opposing Dr. Gill.20 This was the single largest expenditure by a third-party against Dr. Gill. Id.

28. In the final weeks of that campaign, AAN spent $1,157,451 on political advertisements.21 These electioneering broadcast advertisements contained demonstrably false statements, including the claim Dr. Gill would eliminate Medicare, citing in support his 2004 campaign website.22 In fact, however, the website makes clear Dr. Gill's proposals would have expanded Medicare to cover all Americans.23

29. Because AAN was operating as a § 501(c)(4) organization, it did not have to identify the source of its funds for these advertisements. AAN was funded, at least in part, by Aetna and the Pharmaceutical Research and Manufacturers of America (PhRMA). According to a political activity report Aetna, Inc. and Aetna PAC filed in 2012 and inadvertently revealed to the public, Aetna contributed over $3.3 million to AAN in 2011.24 PhRMA reported a grant of $4.5 million to AAN on its 2010 tax return.25

30. Throughout Dr. Gill's race, nearly every poll showed Dr. Gill leading Mr. Davis by margins ranging from one to nine percent.26 In the final weeks of the campaign, however, the huge expenditures by AAN depressed the vote and cost Dr. Gill the race; he lost by 1002 votes, or 3/10th of one percent of the votes cast.27 This was the third closest House race in the nation in 2012, and the narrowest loss by a Democratic candidate. Gregory Giroux, Ten Closest House Races of 2012 -- Starting With 654 Votes, Bloomberg, Jan. 15, 2013.

31. Political spending by a § 501(c)(4) organization also impacted the 2012 10th Congressional District race in California, where Democratic candidate Jose Hernandez was running against Republican incumbent Jeff Denham. Political spending by § 501(c)(4) organizations in that race totaled $2,536,997, or 30.61 percent of all outside spending.28 The top spender was AAN at $2,525,694. Id.

32. Less than three weeks before the election in September 2012, § 501(c)(4) organizations spent $525,213 opposing Mr. Hernandez and supporting his opponent, Rep. Denham. In contrast, no § 501(c)(4) organizations spent money that month opposing Rep. Denham or supporting Mr. Hernandez.29 Other groups joined the fray in October, when § 501(c)(4) organizations poured $2,603,631 into the race in opposition to Mr. Hernandez and in support of Rep. Denham. Conversely, while only $3,634 was spent that month by § 501(c)(4) organizations opposing Rep. Denham and supporting Mr. Hernandez.30

33. Collectively AAN and the U.S. Chamber of Commerce (a § 501(c)(6) organization) spent $3.1 million during the election cycle to help Rep. Denham defeat Mr. Hernandez.31 This far exceeded the $1.7 million Mr. Hernandez was able to raise. Id.

34. When questioned about the negative ads financed by § 501(c)(4) organizations, Mr. Hernandez's campaign manager stated, "It really makes it somewhat unfair where there's no disclosure, because you don't know who's saying what they're saying and why they're saying it." Will Evans, Money From Secret Donors Flows To Congressional Races, California Watch, Oct. 26, 2012.

 

Need For New IRS Rules

 

 

35. As these facts illustrate, increasingly many § 501(c)(4) organizations are spending a significant proportion of their funds on partisan, political activities to affect the outcomes of targeted races. This is the precise type of "direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office" excluded from the definition of the "promotion of social welfare" by Treas. Reg. § 1.501(c)(4)-1(a)(2)(ii). Nevertheless, § 501(c)(4) organizations are able to circumvent this exclusion by relying on IRS regulations that provide, contrary to the statute's exclusivity requirement, such organizations need only be "primarily engaged" in social welfare activities. As a result, there is an increasing influx of "dark" or anonymous money into our political system that is fueled, at least in part, by the ability to keep secret the contributors to § 501(c)(4) organizations.

36. This level of direct or indirect participation in political campaigns by § 501(c)(4) organizations directly contravenes the Code, which grants tax-exempt status -- and the ability to keep secret the identities of donors -- only to "[c]ivic leagues or organizations not organized for profit but organized exclusively for the promotion of social welfare." 26 U.S.C. § 501(c)(4) (emphasis added).

37. This illegal political activity by § 501(c)(4) organizations has resulted in large part from IRS regulations imposing the "primarily engaged" standard and the refusal of the IRS to construe those regulations consistently with the language of the Code, which requires such groups to be "operated exclusively" for the promotion of social welfare. As a result, groups have proceeded on the assumption they can spend up to 49 percent of their total yearly expenditures on political activities and still comply with the requirements of the Code for § 501(c)(4) organizations.

38. Accordingly, it is critical that the IRS act now by promulgating new regulations that comport with the statutory requirement for § 501(c)(4) organizations to be "operated exclusively" for social welfare purposes. In the absence of conforming regulations, there has been a sharply escalating level of political activity by § 501(c)(4) organizations, which has had a direct impact on election outcomes and has changed the landscape of our political campaigns. The IRS must harmonize its regulations with the clear and unambiguous statutory language requiring § 501(c)(4) organizations to be "operated exclusively" for a charitable purpose.

 

Conclusion

 

 

39. Nearly two years ago, in the wake of the Supreme Court's decision in Citizens United v. Fed. Election Comm'n, 558 U.S. 310 (2010), and the 2010 elections, two organizations with extensive experience and expertise in campaign finance laws -- Democracy 21 and the Campaign Legal Center -- petitioned the IRS to revise its existing regulations to make them conform with the statutory requirement that § 501(c)(4) organizations be operated exclusively for charitable purposes. Those petitioners noted the urgency behind their request, given the upcoming 2012 elections.

40. In response, by letter dated July 17, 2012, the IRS indicated its "aware[ness] of the current public interest in this issue," and promised to "consider proposed changes in this area."32 Nevertheless, to date the IRS has refused to act on this petition, allowing the 2012 elections to proceed without any change in the IRS's practices concerning § 501(c)(4) organizations and without any change in its regulations implementing the statutory requirement § 501(c)(4) organizations be operated exclusively for charitable purposes. The results of those elections demonstrate even more compellingly the critical need for the IRS to revise its regulations. Simply stated, the IRS can no longer be silent on a matter that threatens to upend the statutory scheme enacted by Congress. Accordingly, petitioner CREW requests that the IRS act immediately to initiate a rulemaking that will address the serious discrepancies between the Code and IRS regulations defining § 501(c)(4) organizations.

April 9, 2013

Respectfully submitted,

 

 

Anne L. Weismann

 

Melanie Sloan

 

Citizens for Responsibility and

 

Ethics in Washington

 

1400 Eye Street, N.W., Suite 450

 

Washington, D.C. 20005

 

 

Counsel for Citizens for

 

Responsibility and Ethics in

 

Washington

 

FOOTNOTES

 

 

1 Open Secrets, 2012 Outside Spending, Summary (available at http://www.opensecrets.org/outsidespending/index.php) (last visited April 4, 2013).

2 This number is derived by subtracting the $122.9 million spent by § 501(c)(4) groups on the 2012 presidential race, see id., from the total spending by § 501(c)(4) groups in the 2012 election cycle.

3 Open Secrets, 2010 Outside Spending, by Group (available at http://www.opensecrets.org/outsidespending/summ.php?cycle=2010&chrt=V&disp=Q&type=U).

4 Open Secrets, Outside Spending, American Crossroads/Crossroads GPS (available at http://www.opensecrets.org/outsidespending/detail.php?cmte=American+Crossroads%2FCrossroads+GPS&cycle=2012).

5 Open Secrets, Outside Spending, Americans for Prosperity (available at http://www.opensecrets.org/outsidespending/detail.php?cmte=Americans+for+Prosperity&cycle=2012).

6 Open Secrets, Outside Spending, American Future Fund (available at http://www.opensecrets.org/outsidespending/detail.php?cmte=American+Future+Fund&cycle=2012).

7 Open Secrets, Outside Spending, Americans for Tax Reform (available at http://www.opensecrets.org/outsidespending/detail.php?cmte=C90011289&cycle=2012).

8 Open Secrets, 2012 Race: Virginia Senate, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=VAS1). The percentage of outside spending for this and other races cited was derived by determining which groups are § 501(c)(4) organizations and dividing the amount they spent by the total amount of outside spending for and against all candidates, as compiled by the Center for Responsive Politics.

9 Open Secrets, 2012 Race: Nevada Senate, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=NVS1).

10 Open Secrets, 2012 Race: Wisconsin Senate, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=WIS1).

11 Open Secrets, 2012 Race: Ohio Senate, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=OHS1).

12 Open Secrets, 2012 Race: Ohio District 06, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=OH06).

13 Open Secrets, 2012 Race: Pennsylvania District 12, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=PA12).

14 Open Secrets, 2012 Race: Colorado District 03, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=CO03).

15 Open Secrets, 2012 Race: New York District 25, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=NY25).

16 Form 1024, Application for Recognition Under Section 501(a) (available at http://www.scribd.com/doc/50282843/Complaint-CREW-IRS-Investigate-the-American-Action-Network-3-8-11).

17 Statement in Support of Application for Tax-Exempt Status, at 1-2, 4 (available at http://www.scribd.com/doc/50282843/Complaint-CREW-IRS-Investigate-the-American-Action-Network-3-8-11).

18 Letter from the IRS to AAN, April 3, 2010 (available at http://www.scribd.com/doc/50282843/Complaint-CREW-IRS-Investigate-the-American-Action-Network-3-8-11).

19 Open Secrets, Outside Spending, American Action Network (available at http://www.opensecrets.org/outsidespending/detail.php?cmte=American+Action+Network&cycle=2010).

20 Open Secrets, 2012 Race: Illinois District 13, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=IL13).

21 American Action Network, Inc., FEC Form 5, 2012 Year-End Report, January 31, 2013.

22See http://www.youtube.com/watch?v=wc9whvRfmb8&list=PLVOeJbOR9B31WCRe78K0gD3_94Bi0JnyY&index=5.

23See http://webarchive.loc.gov/lcwa0016/20041009161316/ http://www.davidgillforcongress.com/default.htm.

24 CREW, Aetna Hides $7 Million in Political Spending (available at http://www.citizensforethics.org/press/entry/aetna-political-spending-american-action-network-chamber-of-commerce).

25 PhRMA 2010 Form 990, Schedule I, Part II (available at http://www2.guidestar.org/FinDocuments/2010/530/241/2010-530241211-07d129f7-9O.pdf).

26 Huffington Post, Poll Chart, 2012 Illinois House: 13th District (available at http://elections.huffingtonpost.com/pollster/2012-illinois-house-13th-district).

27See Illinois State Board of Elections, November 6, 2012 General Election, at 32 (available at http://www.elections.il.gov/Downloads/ElectionInformation/VoteTotals/2012GEOfficialVote.pdf).

28 Open Secrets, 2012 Race: California District 10, Outside Spending (available at http://www.opensecrets.org/races/indexp.php?cycle=2012&id=CA10).

29 American Action Network, Inc., FEC Form 5, 2012 October Quarterly Report, October 15, 2012.

30 American Action Network, Inc., FEC Form 5, 2012 Year-End Report, January 31, 2013; Crossroads Grassroots Policy Strategies, FEC Form 5, 2012 Year-End Report, January 31, 2013; National Rifle Association Institute for Legislative Action, FEC Form 5, 2012 Year-End Report, January 30, 2013; Voto Latino Action Fund, FEC Form 5, 2012 Year-End Report, January 29, 2013; Communities for a New California-Fresno-Tulane Committee, FEC Form 5, 2012 Year-End Report, March 26, 2013.

31 Open Secrets, 2012 Race: California District 10, Outside Spending.

32 Letter from Lois G. Lerner, Director, Exempt Organizations, IRS, to Fred Wertheimer, President, Democracy 21, and J. Gerald Hebert, Executive Director, Campaign Legal Center, July 17, 2012.

 

END OF FOOTNOTES
DOCUMENT ATTRIBUTES
  • Authors
    Weismann, Anne L.
    Sloan, Melanie
  • Institutional Authors
    Citizens for Responsibility and Ethics in Washington
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2013-8483
  • Tax Analysts Electronic Citation
    2013 TNT 69-16
Copy RID