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Judicial Watch • IRS Pages from May 2015 4760-4764

IRS Pages from May 2015 4760-4764

IRS Pages from May 2015 4760-4764

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dner Lorraine
Fro Hogan James
Sen Friday. April 08, 2011 12:05
To: Gardner Lorraine
Subject: RE: TEGE Referrals 501(c)(4)
Sure._
From Gardner Lorraine
Sent: Friday, April 08, 2011 12:03
To. -logar. James
Subject: RE: TEGE Refenals 501(c)(4) are not fur1ougl1ed_ can have something cob Thursday scone Lori
Fmm: Hogan James
Sent: Friday, April 08, 2011 9:35
To: Gardner Lnrraine
Subject: RE: use Referrals 501(c)(4)
Next Wednesday Thursday thats with your schedule. exible.
Fmm- Gardner Lorraine
Sen iday, April 08, 2011 9:33 Hogan James
Subject: RE: TEGE Referrals 501(c)(4) you want the draft for review? Lori
Sent. Friday, April 08, 2011 9:31
fo: Gardner Lorraine
subject: FW: TEGE Referrals 501(c)(4) our wnversaiion.
Tro Plehl Lisa [mallto:Lisa.M.Piehl@irs.gov]
ien iursday, March 24, 2011 11:46 Hogan James
iubject: TEGE Referrals 501(c)(4)
im, ~.. are receiving referrals from TEGE potential non 501(c)(4) donors. believe that 501(c)(4) ,-I
/arrants review for non- ler EEA Qussion with (by with respect questions raised
reparation TEGE mm!
./10/2011
IRS-JW-220-004
mmi
The IRS has taken the position, via several revenue rulings,
rrrat contributions 501(c)(4) orgzfnizations for social welfare purposes are subject the gift tax
Notwithstanding this position, the area law less settled when the organization involved eandidate~
related activities. result, there are many legal theories that have been developed practitioners
attack the validity the IRS position especially such cases.
The bottom line that the facts each contribution warrants review ascertain compliance with gift tax
laws and may result gift tax non- lers but may also involve signi cant disagreement from some contributor
representatives.
Lisa elif
Estate and Gift Policy Manager
5340 Variel
Woodland Hills, 91367
Cell: (BY
Fox:818 226-9902
Oct ber15,201D
Forbes: Are Contributions 501(c)(4) Groups Subject the Gift Tax?
Forbes, gmgr pot ogt The 354 lim Beg the run-up next months eiedions, big and controversial development has been the ability tycoons make
unlimited political donations without any public disclosure whatsoever. This done giving the money certain
501(c)(4) organizations named for the tax-oode provision establishing their status. Right now the best-known 501
(exit) Qws m. Grassroots GPS, set SeVa Political operative
Karl Rove.
The makes clear that such contributions are not deductible the donor from personal
federal income taxes. But that may not the whole story from tax perspective. Los Angeles tax lawyer telling
clients such gills could subject the federal gilt tax, which hefty 35% this year but scheduled rise
weightier 55% January memo, tXgLLim1, lawyer with Mitchell Sllberberg Knapp who specializes nonpro organizations, writes
that unlike contributions certain other pol cal organizations, there giftvtax exemption written into federal law
for contributions 501(c)(4)s, which the IRS: ciaily dassi sooi_aI weltare organizations but also are otter:
used for lobbying. And that. says, raises the possibility that down the road the IRS might come calling for the tax,
plus interest, plus penalties. The lRS may well irresistible the potential revenue raised from assessing gitt
taxes 501(c)(4) conlrributorsf writes Lion. spokesman for Crossroads GPS, which based Washington, D.C., said Thursday had never heard anything
about possible gilt tax liability 501 (c)(4) contributions until Forbes called, and did not know his organization
had written legal opinion specifying why there would liability for its donors.
But news reports are correct, well heeed individuals are making muiti~miliion donations 501(c)(4)s, which would
blow through any yearty lifetime exemptions. its also not hard imagine that the level giving tax-averse
moguls might way down ltthe threat gilt-mx liability not negated.
Lion writes that there Indication now the IRS intends oollect the gift tax 501(c)(4) contributions, and that
there might First Amendment issue tried. But notes the agency wouldnt have dil cuit research task
./10/2011
IRS-JW-220-004
Nhile there public disclosure donors 501(o)(4) presumed part the appeal for manyfiederal law
requires 501(o)(4) reveal the IRS the names all donors $5,000 and up. The easy-louse lists would
treasure trove tor the IRS, Lion declares.
Although have not seen Mr. Lions memo, certainly correct that lhe 25_0 )l1 tl5Et 3XLXC,llJSL0lLf0l Ooniributions
political organizations does not apply transfers 501(c)(4) groups like Crossroads GPS. But note the Teacher
Manual accompanying our casebook (lgdej:-a gal Irmsfe xaion (Foundation Press, 6th ed. 2009)). theSe types
political contributions should not subject the gift tax any event because the lack true donative Intent the part the
contributors developed the oaselaw prior the enactment 2501(a)(4). See also Kip Dellinger, Gift Tax Political
Contributions? Lousy Idea], Tax Notes 621 (1998).
Big ll) Donations
Gift Ta); j10l1N101:37
Interesting new development the shadowy wortd 501(c)(4) spending. Forbes 1s_Lep_amng, that t.os Angeles tax lawyer
advising clients that their contributions 501(c)(4) groups could subject weighty percent federal grtt tax memo, Ofer Lion, lawyer with Mitchell Silberber who specializes nonpro organizations, writes
that unlike contributions certain other political organizatltinsthere gift-tax exemption written into federal law
for oontributions 501(c)(4)s. which the IRS oialty classi sooialwvelfare organizations but also are often
used for lobbying. And that, says, raises the possibility that down the road the lntemal Revenue Service might
come calling for the tax. plusjnlerest, plus penalties. The IRS may well irresistible the potential revenue
raised from assessing gift taxes 501(c)(4) oontnbutors, writes Lion.
vat every contribution quali for gift tax married couples, for instance, can give $26,000 year many recipients
hey want without incurring tax, and individual taxpayers also enjoy lifetime exemption million before incurring tax. But
eports muiti-million dollar contributions wealthy individuals some 5D1(r:)(4)s are correct, they would easily surpassing threshold and could dissuaded the tax from giving more.
spokesmen for ssroads GPS. popular outside group spending heavily behalf Republicans this midterm cycle, and even IRS. for that matter, appeared ummoxed ques regarding possible gift tax liabil for oontributions 501 (cm)
yroups. its not everyday the IRS responds saying, Thats interesting issue, and asking for more time look into the
nafter. oontlnued, seems.
nteres new development the shadowy world 501(c)4 spending. Forbes rmg that Los Angeles tax
awyei advising clients that their contributions 501(c)4 groups, like Des Moines-based Lind,
x)uld subject weighty percent federal tax. memo, Ofer Lion, lawyer with Mitchell Silberberg Knupp who specializes nonpro
organizations, writes that unlike contributionsto political organizations, there -tax
exemption written into federal law for contribuuonsit5 )i( )(4) which the IRS officially classi
social welfare organizations but also are used for ll3 bying. And that, says, raises the possibility
that down the road the Internal Revenue Service might come calling for the tax, plus interest, plus penalties.
The IRS may well irresistible the potential revenue raised from assessing gift taxes 501(c)(4)
cont.nbutors, writes Lion.
lot every contribution quali for tax married couples, stance, can give $26,000 year many
acipients they want without incurring tax, and individual taxpayers also enjoy lifetime exemption million
9/IO/2011
IRS-JW-220-004792
before incumng tax. But reports multi million dollar contributions wealthy individuals some 501(c)(4)s are
concct, they would easily surpassing the threshold and could dissuaded the tax frorn giving more.
Spokesman for Crossroads GPS, popular outside group spending heavily behalf Republicans ijliis midiemi cycle,
and even the IRS, for that niattcr, appeared ummoxed questions regarding possible gift tax liability for
contzibutions 501(c)4 groups. not everyday the IRS responds saying, Tl131 m35l issues and asking
for more time look into the niatter. continued, seems. b)( 5;)
;/10/zoii
IRS-JW-220-004
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