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Clergy Seek IRS Probe of Lawmakers' C Street Center

FEB. 23, 2010

Clergy Seek IRS Probe of Lawmakers' C Street Center

DATED FEB. 23, 2010
DOCUMENT ATTRIBUTES

 

February 23, 2010

 

 

The Honorable Douglas Shulman

 

Commissioner

 

Internal Revenue Service

 

1111 Constitution Avenue N.W.

 

Washington, D.C. 20224

 

 

Dear Commissioner Shulman:

We, the undersigned members of Clergy VOICE, are writing to express our concern regarding potential tax abuse committed by the long extant and secretive organization, C Street Center, Inc. (the "C Street Center"), that operates a housing facility for Members of Congress in the Capitol Hill neighborhood of Washington, D.C. Clergy VOICE is an ad hoc group of clergy concerned with the unconstitutional enmeshment between church and state. We write as individual clergy and not as representatives of any congregation, judicatory or denomination. Among us are clergy standing within the following religious traditions: the American Baptist Churches/USA; the Christian Church (Disciples of Christ); the Episcopal Church; the Evangelical Lutheran Church in America; the United Church of Christ; and the United Methodist Church.

We write to challenge the C Street Center's self-proclaimed status as a church for federal tax purposes. Based on publicly available information, we wonder how the C Street Center could possibly qualify as a church under section 170 of the Internal Revenue Code1 or even as a tax-exempt organization under section 501(c)(3). We fear that by holding itself out as a church, the C Street Center poses a threat to the integrity and legitimacy of the charitable, organizational, historic, ecclesiastical, and worship activities of all religious organizations in the United States.

As we understand it, C Street Center has no recognized creed or form of worship, no distinct ecclesiastical government, and no formal code of doctrine. To the best of our knowledge, it is not led by ordained ministers, and its leadership is not selected based on the completion of any prescribed studies for the preparation of ministers. We are not aware of it holding regular religious services that are open to the public, it has no Sunday schools for religious instruction of the young, and it has no distinct religious history.

It is evident -- based on multiple press reports and the District of Columbia's recent decision to revoke the majority of its property tax exemption -- that C Street Center is not a church. Rather, it is a boarding house allegedly providing low-cost room and board to Members of Congress. An organization whose chief activity is providing room and board to Members of Congress is not a church.

C Street Center's activities are shrouded in secrecy. Its powerful residents reportedly adhere to a "code of silence."2 Thus, it is unclear whether the C Street Center serves any ecclesiastical functions other than organizing counseling for political officials confronting personal scandals and potential civil or criminal investigations. According to the Washington Post, the C Street Center and its residents have ensured that "what went on inside stayed inside."3 This lack of transparency shows a disdain for the political, legislative and economic accountability that define constitutional democracy.

If C Street Center's classification as a church is not challenged by recognized, ordained members of the clergy, then the charitable and religious activities of all legitimate houses of worship are jeopardized at great cost to the beneficiaries of those activities. The clear boundaries between religion and government guaranteed by the Constitution of the United States offer the best protection of religious freedom and diversity of belief that the Founders could foresee. Those same boundaries exist to protect a fundamental public trust. When any organization misrepresents itself as a "church," in order to achieve exemption from taxation, as well as from legal and financial transparency, then the gate to corruption is opened wide. On one hand, the boundary between church and state exists to protect religious freedom. But it also serves to guard against religion's corruption of the government, through, for instance, the abuse of power, the distortion of legislative process, and the rise of secret foreign policy initiatives that have been widely documented, and will continue in perpetuity, as long as C Street Center is permitted to remain classified by the Internal Revenue Service (the "IRS") as a church.

The questions articulated, the fact patterns displayed, and the demand for examination presented in the following tax analysis are of great import to all persons concerned with the protection of religious freedom and constitutional democracy as it was conceived by the Founders.

I. Factual Background about C Street's Operations

The C Street Center (EIN 52-1251896) holds itself out as a section 501(c)(3) public charity. Specifically, the organization claims to qualify as a "church" under section 170(b)(1)(A)(i).4 In accordance with church-tax status, the organization does not file annual information returns, Form 990s, with the IRS.

The C Street Center operates a residential housing facility, located at 133 C Street SE in Washington, D.C. The property is a three-story rowhouse located in the Capitol Hill neighborhood, only steps from the Congressional office buildings. The District of Columbia tax records reflect that the house has a total of 5,732 square feet.5 Its assessed value for tax purposes in 2009 was $1,844,810. According to press reports, the house includes twelve bedrooms, nine bathrooms6 and five living rooms (including one with a big-screen TV).7 The house is primarily used as living quarters for Members of Congress. According to press reports from 2003, Reps. Zach Wamp (R-Tenn.); Bart Stupak (D-Mich.), Jim DeMint (R-S.C), Mike Doyle (D-Pa.), and Sens. John Ensign (R-Nev.) and Sam Brownback (R-Kan.) lived in private rooms in the C Street house. Current residents include Wamp, Stupak, Doyle, Ensign, and Sen. Tom Coburn (R.-Okla.).8

In 2002, according to press reports, each resident paid $600 per month in rent. Living accommodations include cleaning services provided by eight college-age volunteers and a "house mother," apparently in a manner analogous to a bed and breakfast or similar commercial lodging facility. Meals reportedly cost extra, but it is unclear whether they are subsidized as well.9 The press reports from 2002 are not conclusive in establishing that Members of Congress are receiving below-market rent in light of the accommodations and services provided, but they do provide ground for further inquiry as furnished living quarters with maid service, such as those provided by a bed and breakfast, typically cost significantly more than the rent allegedly charged to the C Street Center tenants.

Press reports indicate that the C Street Center hosts prayer breakfasts and dinners for Members of Congress on a weekly basis, as well as an annual "Ambassador Luncheon." We were unable to locate any information regarding other religious services (including any services open to the general public) or the ecclesiastical teachings of the organization. The official biographies of the known current and former residents indicate that they profess a variety of faiths, including several Protestant denominations and Catholicism.10

Until recently, the C Street Center also claimed a religious exemption from District of Columbia property taxes. In the fall of 2009, however, that status was partially revoked, and the property is now listed in District tax records as taxable residential property.11 According to a public statement by a city official: "The property in question was inspected by our office . . . and it was determined that portions are being rented to private individuals for residential purposes. As a result, the exemption was partially revoked and adjusted so that only 34 percent is now tax-exempt and 66 percent has become taxable."12

II. C Street Center Does Not Appear to Qualify as a Church.

The C Street Center claims to be exempt from tax as a church under sections 501(c)(3) and 170(b)(1)(A)(i). However, the media reports described above and the District of Columbia Board of Tax Assessment's decision to revoke the majority of the property's tax exemption raise serious questions about whether the organization is appropriately classified as a church.

As a threshold matter, an organization must satisfy the requirements applicable to all organizations exempt from tax under section 501(c)(3) -- including the rules limiting private benefit and prohibiting political intervention by these organizations -- before it can claim to be a church.13 Beyond this threshold, Congress has never defined the standards an organization must meet to be classified as a "church" for purposes of the Internal Revenue Code.14 In the absence of a statutory definition, however, the IRS has developed fifteen criteria by which it determines whether an organization qualifies as a church.15 The factors used by the IRS to determine whether an organization is a church are:

 

1. Whether the organization has a distinct legal existence;

2. Whether it has a recognized creed and form of worship;

3. Whether it has a definite and distinct ecclesiastical government;

4. Whether it has a formal code of doctrine and discipline;

5. Whether it has a distinct religious history;

6. Whether it has a membership not associated with any other church or denomination;

7. Whether it is an organization of ordained ministers;

8. Whether ordained ministers are selected after completing prescribed studies;

9. Whether it has a literature of its own;

10. Whether it has established places of worship;

11. Whether it has regular congregations;

12. Whether it holds regular religious services;

13. Whether there are Sunday schools for religious instruction of the young;

14. Whether there are schools for the preparation of ministers; and

15. Any additional facts and circumstances that may be relevant.

 

Recently, the Court of Federal Claims analyzed whether the Foundation of Human Understanding ("FOHU"), an organization purporting to be a church, actually qualified for church status.16 In determining that FOHU failed to qualify as a church, the court noted that an organization need not satisfy all of the IRS's criteria and that no single factor is controlling. The court, however, focused on the "associational test" arising from the IRS's factors. Specifically, the court determined that three factors -- a regular congregation, regular religious services, and religious education for the young -- are of "central importance" because they suggest an "associational role" that distinguishes churches from other religious organizations. Similarly, courts have also explained that private religious beliefs practiced in solitude do not render a residence into a church:

 

"At a minimum, a church includes a body of believers or communicants that assembles regularly in order to worship. Unless the organization is reasonably available to the public in its conduct of worship, its educational instruction, and its promulgation of doctrine, it cannot fulfill this associational role."17

 

As leaders of churches across America, we have serious doubts about whether the C Street Center meets the standards described above. At bottom, it does not appear to be a house of worship "reasonably available" for the public to use. We are aware of no reports of the C Street Center conducting religious education for the young, holding services for the masses or promulgating religious teachings. While press reports indicate that the C Street Center holds religiously-based events for Members of Congress, hosting events for dignitaries is very different from shepherding a flock of congregants. Furthermore, we were unable to locate any reports that suggest the C Street Center might meet the other factors that the IRS considers in determining whether an organization qualifies as a church -- including factors such as a recognized creed and form of worship, an ecclesiastical government, a formal code of doctrine and discipline, a "distinct religious history," an organization of ordained ministers, a literature of its own and so on. In fact, given that the Member residents reflect a variety of different faiths, it seems unlikely that a particular creed or set of religious teachings are promulgated by the Center. Finally, the District of Columbia Board of Tax Assessment evaluated whether the C Street Center was entitled to a property exemption based on its religious activities and determined that the majority of the house is rented for private residential purposes -- rather than used in conducting religious services.18

In light of the media reports and the District of Columbia's recent decision, we are concerned that an exclusive residential club for powerful officials may be masquerading as a church. Anytime an organization uses church status as part of a tax avoidance scheme, it poses a threat to the integrity of religious institutions everywhere. Because the C Street Center clearly presents such a threat, we respectfully request that an appropriate Treasury official evaluate whether there is a reasonable belief that the C Street Center is not, in fact, exempt from tax as a church and, if the official determines that such a belief exists, authorize a Church Tax Inquiry to determine the appropriate classification of the organization.

III. The C Street Center Does Not Appear to Meet the Requirements Generally Applicable to Section 501(c)(3) Organizations.

Because of its purported status as a church, the C Street Center has never filed annual information returns (i.e., Form 990s) detailing its finances and activities. Therefore, we do not have a complete picture of whether it satisfies all of the relevant tax rules. However, there are indications that the C Street Center's operations may violate several rules that prevent an organization from qualifying for tax-exempt status under section 501(c)(3) -- namely the rules preventing an organization from furthering a substantial non-exempt purpose, benefiting private parties or operating in violation of public policy. These rules would also be applicable regardless of whether the IRS determined that the C Street Center qualified as a church or if the organization conceded that it was not, in fact a church, but rather asserted that it was a religious organization exempt under the general rules of section 501(c)(3).

 

A. The C Street Center Appears to Fail the Operational Test Because a Substantial Portion of its Activities Further a Nonexempt Purpose.

 

Under section 501(c)(3), exemption from federal income tax is limited to organizations "organized and operated exclusively" for religious or other charitable purposes, "no part of the net earnings of which inure to the benefit of any private shareholder or individual." If a substantial part of an organization's activities is not in furtherance of an exempt (i.e., charitable or religious) purpose, the organization will not qualify for tax-exempt status.19 Clearly, providing room and board to individual Members of Congress is not a charitable purpose. Therefore, if the boarding house activity represents a substantial part of the C Street Center's activities, it fails the operational test.

In determining whether a particular activity is substantial in relation to an organization's overall activities, the IRS generally examines the amount of income derived from the activity, the amount of expenditures dedicated to it, and the amount of time the organization's employees devote to it. Because the C Street Center does not file information returns, we do not have a complete picture of its finances and operations. However, the District of Columbia government's revocation of 66% of its tax exemption suggests that at least 66% of the C Street property is used as residential property -- in other words, it is not used in furtherance of a charitable or religious purpose. By all accounts, the C Street Center only conducts activities at that one location. If 66% of its sole property is used for a non-exempt purpose, it is probable that a substantial part of the organization's activities are in furtherance of a non-exempt purpose, which would prevent the C Street Center from qualifying under section 501(c)(3).

 

B. The C Street Center May Provide Significant Private Benefit to its Residents, Rather than the General Public.

 

An organization is not considered organized or operated exclusively for exempt purposes unless it serves a public, rather than a private, interest.20 The Supreme Court has held that the presence of "private benefit," if substantial in nature, will disqualify an organization from tax-exempt status, even if it also carries on religious or charitable activities.21 "Private benefit" means "nonincidental benefits conferred on disinterested persons [i.e., people who do not control the organization] that serve private interests."22

The provision of a valuable benefit, including, for instance, below-market room and board, to a group of individuals constitutes a private benefit unless 1) the beneficiaries are members of a charitable class and 2) the activities of the organization benefit them in a nonselective manner.23 Providing room and board to Members of Congress, if the amounts charged are below market, quite clearly fails both of these requirements. Members of Congress -- who earn $174,000 per year -- do not constitute a charitable class. Moreover, the C Street Center rooms are not available for the general public to rent and, by all appearances, are not rented out in a "nonselective manner." Therefore, if the C Street Center is providing below-market room and board to certain Members of Congress, the organization would appear to be conferring a private benefit on these individuals.

Furthermore, if the C Street Center is indeed providing below-market room and board, the private benefit would not appear to be insubstantial or incidental to whatever public benefit is created by the C Street Center. Unless the private benefit is considered insubstantial both quantitatively and qualitatively, the organization cannot qualify for tax-exempt status.24 To meet the qualitative standard, the organization must show that the private benefit is a necessary concomitant of activity that primarily benefits the public at large.25 It is unclear how using its property as living quarters for Members of Congress could be a necessary part of the C Street Center's religious activities. To meet the quantitative standard, an organization must show that the private benefit conferred by an activity is insubstantial compared to the public benefit created by it.26 Yet, as we noted above, the C Street Center appears to use most of its property as congressional living quarters -- a fact that suggests the organization fails the quantitative standard as well.

 

C. The C Street Center's Potential Violations of the Congressional Gift Rules May Violate Public Policy.

 

Additionally, the C Street Center's provision of room and board to Members of Congress, if not at full market price, would violate the congressional ethics rules and potentially have ramifications for the organization's tax-exempt status.

House and Senate ethics rules generally prohibit Members of Congress from accepting any gift with a value in excess of $50. A gift is defined as any gratuity, favor, discount, hospitality, or other item having monetary value, for which the Member does not pay full market value -- including the provision of lodging and meals -- whether provided in kind or otherwise.27 A number of exceptions exist, but none that would be likely to apply in this situation. For example, Members may accept "food, refreshments, lodging, and other benefits" if resulting from the Member's outside business or employment activities, but the benefits must not be offered or enhanced because of the Member's official position and they must be "customarily provided to others in similar circumstances."28 Hospitality may be provided by an individual on the basis of a personal friendship, but not by any organization.29 If Members of Congress are accepting room and board from the C Street Center without paying full market value for the benefit, they would be violating the gift rules.

The gift rules are internal rules that regulate the conduct of Members of Congress, but generally are not binding on private citizens. Among non-Members of Congress, only registered lobbyists and organizations that employ lobbyists are subject to legal sanctions for knowingly violating the House and Senate ethics rules.30 Nonetheless, a rampant violation of the congressional gift rules would likely cause an organization to lose its tax-exempt status. The Supreme Court has held that conduct that violates fundamental public policy, even if not illegal per se, is inconsistent with tax-exempt status.31 Chronic, deliberate violations of the congressional gift rules would certainly constitute a violation of public policy.

Moreover, in the event that this room and board were being subsidized by C Street Center and donors to the organization have business before Congress, there may be further -- and more serious -- implications for the residents of the C Street Center. Namely, underwriting the living arrangements described above through the C Street Center could be providing for-profit organizations and private individuals with a means to provide these particular benefits to Members of Congress in circumvention of the limits or prohibitions imposed by Congressional ethics rules and federal law. Concerned about similar inappropriate for-profit influence, Senator Grassley has recently expressed an interest in knowing whether health charities are supported by the healthcare and insurance industries.32 And even more significantly, this kind of arrangement could potentially have criminal implications. For instance, in US v. Randall Harold Cunningham, Crim. Case No. 05cr2137-LAB, Randall "Duke" Cunningham pled guilty to receiving personal benefits from lobbyists, and likewise, the prosecution and conviction of Jack Abramoff and his associates both in and out of government featured several instances of apparent use of nonprofit entities to launder travel, gifts, and other benefits provided to government officials by Abramoff and other lobbyists.33 These possibilities further compel an IRS investigation to determine whether this kind of subsidy is, in fact, occurring.

IV. The C Street Center Does Not Appear to Qualify as a Public Charity Under Section 509(a).

Even if the C Street Center does not qualify as a church, it is possible that the organization may assert that it is a tax-exempt religious organization under section 501(c)(3) and that it qualifies as a public charity under section 509(a), other than as a church. In addition to the rules discussed above in Section III that we believe would prevent the organization from qualifying as exempt under section 501(c)(3), it is likely that the C Street Center would face difficulties qualifying as a public charity. As we noted above, the C Street Center does not file annual Form 990s, and, thus, we have no concrete figures regarding its funding. However, if the organization receives the vast majority of its funding from non-exempt income (i.e., the room and board payments from Members of Congress) and is not classified as a church, it would likely fail the public support test of either section 509(a)(1) or 509(a)(2). Likewise, if the organization receives "contributions" from only a small group of zealous donors -- like its residents -- it would also likely fail both of the public support tests.

Organizations that are not treated as per se charities qualify as public charities by virtue of their funding -- if an entity receives more than 33 1/3% (or in some cases 10%) of its support from certain public sources, it may qualify as a public charity.34 There are a number of technical rules for determining whether an organization's receipts are from public sources, but payments for room and board that are not related to the organization's exempt purposes do not qualify as "public support" under these tests. Assuming that the great majority of the C Street Center's income is from these sources -- rather than from gifts or contributions from a large number of unrelated donors, for instance -- it is unlikely the organization qualifies as a public charity. If the organization does not qualify as a public charity, but is otherwise exempt from tax under section 501(c)(3), it will be treated as a private foundation.

V. If Classified as a Private Foundation, the C Street Center Fails the Self-Dealing Prohibition In its Transactions with Members of Congress

If the C Street Center were to assert exemption as a religious organization other than a church and it failed the public support test described in Section IV, it would be treated as a private foundation. Private foundations are prohibited from engaging in self dealing transactions described in section 4941. Self dealing transactions are those transactions between the foundation and certain disqualified persons described in section 4946. Specifically, government officials (including elected officials, like Members of Congress) are disqualified persons for the purposes of these rules.35 These rules prohibit a private foundation from engaging in any transaction with a government official unless the transaction qualifies as an exception specifically enumerated in the Code or Treasury Regulations. Under these rules, providing room and board -- whether for fair value or not -- is considered a self-dealing transaction.36

The penalties for self-dealing transactions are threefold: (i) an excise tax on the government official if he participates in the transaction knowing it is an act of self-dealing; (ii) an excise tax on any foundation manager who knowingly approves the transaction; and (iii) for a flagrant, willful act or willful, repeated violations, revocation of the organization's tax-exempt status.37 Thus, if the C Street Center were treated as a religious organization that is a private foundation, it would engage in self-dealing by the act of providing room and board to Members of Congress. The foundation managers and Congressional residents would almost certainly be subject to the excise tax, and the C Street Center itself would likely have its tax-exempt status revoked.

VII. Conclusion

Freely available public information has alerted us to a number complicated and significant questions regarding the tax status of the C Street Center. As religious leaders of our own legitimate churches, we object strenuously to any perversion of the tax laws applicable to churches that allows private or partisan political gain. Based on the media reports surrounding the C Street Center and the District of Columbia's recent partial revocation of its property tax exemption, we have no choice but to question whether tax abuse involving Members of Congress is occurring in this situation. In light of the foregoing, we respectfully request that the IRS initiate a Church Tax Inquiry into the operations of the C Street Center to determine the organization is appropriately classified as a church under section 170(b)(1)(A)(i) or, indeed, even entitled to tax-exempt status under section 501(c)(3). We greatly appreciate your cooperation in this matter.

Sincerely,

 

 

Name: __________________________

 

Signature: _____________________

 

Title: _________________________

 

Date: __________________________

 

Enclosures

 

 

cc:

 

Director, EO Examinations

 

FOOTNOTES

 

 

1 Unless otherwise noted, all section references herein are to the Internal Revenue Code of 1986, as amended, (the "Code") or the Treasury Regulations thereunder.

2 Manuel Roig-Franzia, The Political Enclave that Dare Not Speak Its Name, Wash. Post., June 26, 2009.

3Id.

4 In the IRS Business Master File, the reason given for the organization's non-private foundation status is that it is an organization described in section 170(b)(1)(A)(i). See Charity Check, attached as Exhibit A.

5 See "Property Detail" and "Property Features" for 133 C St. SE (Square 0733, Lot 0825), attached as Exhibit B. This information is available by searching the District of Columbia's Real Property Assessment Database at https://www.taxpayerservicecenter.com/RP_Search.jsp?search_type= Assessment.

6 District of Columbia tax records suggest that there are only six bathrooms. See "Property Features," supra note 5.

7 Lisa Getter, Showing Faith in Discretion, L.A. Times, Sept. 27, 2002; Roig-Franzia, supra note 2; Lara Jakes Jordan, Religious Group Helps Lawmakers With Rent, Associated Press, April 20, 2003.

8 Getter, supra note 7; Roig-Franzia, supra note 2.

9 Getter, supra note 7.

10 Rep. Wamp (Baptist), Rep. Stupak (Catholic), Rep. DeMint (Presbyterian), Rep. Doyle (Catholic), Sen. Ensign (Christian), Sen. Brownback (Catholic) and Sen. Coburn (Baptist),

11See "Property Detail," supra note 5.

12 Al Kamen, It's Official: The C Street House is Not a Church, Wash. Post., Nov. 18, 2009. Partial property tax exemptions are typically based on the percentage of square footage used for exempt and non-exempt purposes. This suggests that 66 percent of the house is used as living quarters for Members of Congress, while the remaining 34 percent is used for religious activities.

13See, e.g., G.C.M. 38699 (Apr. 23, 1981).

14 "Integrated auxiliaries" of churches generally enjoy the same legal privileges as churches. However, to be considered an integrated auxiliary, an organization must be affiliated with a church or a convention or association of churches. We are not aware of affiliations between the C Street Center and any other church.

15 Internal Revenue Manual § 7.26.2.2.4.

16Foundation of Human Understanding v. United States, 104 A.F.T.R.2d 2009-5424 (Fed. Cl. July 21, 2009).

17American Guidance Found., Inc. v. United States, 490 F. Supp. 304, 306 (D.D.C. 1980), aff'd in unpublished opinion (D.C. Cir. 1982).

18See "Property Detail," supra note 5; Kamen, supra note 12.

19 Reg. § 1.501(c)(3)-1(c)(1).

20Reg. § 1.501(c)(3)-1(d)(1)(ii).

21See Better Business Bureau v. United States, 326 U.S. 279 (1945).

22American Campaign Academy v. Comm'r, 92 T.C. 1053, 1069 (1989); Rev. Rul. 2006-27, 2006-21 I.R.B. 915.

23American Campaign Academy, 92 T.C. at 1077.

24See IRS General Counsel Memorandum 37789 (Dec. 18,1978).

25 IRS General Counsel Memorandum 39862 (Nov. 22, 1991).

26See Rev. Rul. 70-186, 1970-1 C.B. 128.

27 Senate Rule 35, cl. 1; House Rule 25, cl. (5)(a).

28 House Rule 25, cl. 5(a)(3)(G)(i) (emphasis added).

29See H. Comm. on Standards of Official Conduct, House Ethics Manual (2008 ed.) at 61-63.

30See 2 U.S.C. § 1613.

31Bob Jones Univ. v. United States, 461 U.S. 574 (1983).

32 In December 2009, Sen. Grassley sent letters to thirty-three medical organizations inquiring into their financial backing from the pharmaceutical, medical device, and insurance industries. See http://grassley.senate.gov/news/Article. cfm?customel_dataPageID_1502=24413.

33See S. COMM ON FINANCE, MINORITY STAFF REPORT: INVESTIGATION INTO JACK ABRAMOFF'S USE OF TAX-EXEMPT ORGANIZATIONS (S. PRT. NO. 109-68, October 2006).

34 I.R.C. §§ 509(a)(1), (a)(2), 170(b)(1)(A)(vi).

35 § 4946(c).

36 § 4941(d)(1)(A).

37 §§ 4941, 507(a)(2).

 

END OF FOOTNOTES
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