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Judicial Watch • JW v IRS 01559 unredacted documents – pg 19-29

JW v IRS 01559 unredacted documents – pg 19-29

JW v IRS 01559 unredacted documents – pg 19-29

Page 1: JW v IRS 01559 unredacted documents – pg 19-29


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Date Created:May 2, 2018

Date Uploaded to the Library:May 02, 2018

Tags:Kerner, Stuber, elise, Kindell, IRS unredacted, 2018, laura, Lois Lerner, 01559, Judith, Nikole, Brown, Lerner, Henry, SUSAN, treasury, IRS

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Meeting 4/30/13
Capitol Hill staff
Laura Stuber (Majority Senior Counsel)
Elise Bean (Majority Staff Director and Majority Chief Counsel)
Henry Kerner (Minority Staff Director and Minority Chief Counsel)
Stephanie Hall (Minority Counsel)
Scott Wittmann (Minority Research Assistant)
Aaron Fanwick (Majority Law Clerk)
Nikole Flax
Lois Lerner
Nan Marks
Janine Cook
Susan Brown
Catherine Barre
Suzanne Sinno
Judith Kindell
Laura Stuber asked about the office structure. Lois Lerner explained that she
oversaw three main functions. CEO managed our website, coordinated our public
speaking appearances and created our brochures and other publications. The Exam
function, addition doing traditional exams (or audits) also had other units. One
the Review Operations (ROO) which generally looks public information without
contacting the organization see there issue with the organization and, so,
refer for examination. Their work generated from several sources. For example, examine organization and they are generally compliant but there were some
issues discovered during the exam, the ROO will follow-up see the
organization continues compliant. The ROO also does the hospital community
benefit reviews mandated the ACA. The ROO also will post-determination
review random sample organizations who were recognized exempt the
IRS. They also review organizations flagged the Determinations function the
Determinations agent sees issues concern when reviewing the application that are
not sufficient warrant denial the application. The ROO one function the
Exempt Organization Compliance Area (EOCA). The other function the EOCA the
Exempt Organization Compliance Unit (EOCU). The EOCU does compliance checks
where they may asking organization for information missing from Form 990.
The also send out compliance check questionnaires, where gather information from large number organizations. have used these for hospitals, credit counseling
and colleges and universities. These are not exams, the organizations are not
required respond, but may refer them for exam they not. generally
get very high response rate, 95% 98%. make the questionnaires public that
even those that dont get the questionnaires can see what are interested in.
generally issue public report our findings from the questionnaire. also may
select some organizations for exam based information the questionnaire, their
Form 990 filings and other information. The EOeU sends out the questionnaire and
may some the data analysis.
Henry Kerner asked how many people work the ROO. Lois Lerner did not have the
numbers but could get them. our latest annual report stated that there were 516 Exam employees. Henry Kerner asked how many questions were the
questionnaires. Lois Lerner said that depends. have couple active
questionnaires out now and available our website. They are being done
electronically, that the organization only sees the questions that are relevant them. the eU questionnaire, sent 400 organizations and asked questions their
demographics, possible UBI activities, compensation and investment practices.
Elise Bean asked were looking into section 501 (c)(4) organizations that were
engaged political campaign activities. Lois Lerner said that our self-declarers
questionnaire asked about lots things, most relating the tax year their most
recently filed Form 990 (either 2010 2011). also included section asking about
any political campaign activities calendar year 2012, which would not otherwise
have since their 2012 Form 990 not yet due. The questionnaire was sent all
self-declared section 501 (c)(4), (5) and (6) organizations that filed Form 990. Elise
Bean asked about the scope the universe. Nikole Flax clarified that the
questionnaires were only sent organizations that filed Form 990 2010 2011 and
not the organizations that filed Form 990-EZ Form 990-N. Laura Stuber asked what
the deadline for responding the questionnaire was. Lois Lerner explained that the
questionnaires were not all sent once because the staff could not handle it, but were
sent out waves. The organizations are given days respond, but may request
extension, could 90-120 days before they respond The last the
questionnaires went out last week. Henry Kerner asked had received any
responses yet. Lois Lerner said she was sure had but had not checked. Henry
Kerner asked about the process and whether checked any the answers the
questionnaire. Lois Lerner explained that dont verify the responses, report
what are told the organizations. select for examination organizations that
appear have issues. the eU study, looked compensation and UBI issues
and selected organizations for exam based upon information the questionnaire and
their Form 990. Henry Kerner asked about checking with other organizations. Lois
Lerner explained that other organizations may define things differently. had
situation few years ago where someone referred organization based upon their
reporting another agency. When looked the information, determined there
was issue because the other agency had different definition. There also the
issue the timing the reporting. For example, the FEe has real time reporting. The
reporting the IRS looks previous years. That why the self-declarers
questionnaire asked about 2012 data wont getting the Forms 990 for
some time. putting together the questionnaires, work with our Research function ensure that are getting information that can apply the universe being
studied. some instances, this will mean asking the question little differently. They
also help ensure that have statistically valid sample that can take the
information learned and make broad statements about the universe. For the
organizations select for exam, this not statistically valid sample. Therefore, the
observations make based upon the exams apply only those organizations
examined. When report our findings, note any trends and concerns raised
well any next steps will taking. Stephanie Hall asked whether the final report
would identify organizations name, Lois Lerner said no. Henry Kerner asked
whether exam and audit were the same and Lois Lerner said yes.
Elise Bean then asked about the third function the Division. Lois Lerner said this
was the Rulings and Agreements function. This includes the Determinations function,
which processes the applications for recognition exemption.
Elise Bean said that they were trying get the scope the universe they were dealing
with and asked what the breakdown the organizations that received the self-declarers
questionnaire. Lois Lerner said that she did not have it, but could get it.
Lois Lerner explained that the general exam function did traditional audits. There are
various sources for these audits. Some them arise out our projects, like the CU
project. also are using the Form 990 data develop risk models. also get
referrals, both internal and external. The external referrals come from the public, the
press and Congress. When receive referral, have classification unit that
reviews the allegation see there indication that the organization may not
compliance. While most cases are reviewed single classifier, some referrals are
reviewed committee experienced, career civil service employees. These are the
more complex sensitive issues. the classifier review committee determine that
there issue the referral that warrants examination, they will send the
examination function. That does not necessarily mean that exam will opened
immediately. must wait for the Form 990 filed audit returns, not
organizations. also need have agent available work the case with the
appropriate level experience.
Laura Stuber asked could deny organization extension for filing Form 990 are waiting the filing open the audit. Lois Lerner said that could not. The
first extension automatic and the second extension granted the organization has reasonable explanation for why needs the extra time. Lois Lerner did note that
were discovering errors filling out Form 990. The better the information the form,
the better are case selection. have found cases where the organization filled the
form out incorrectly and were selected for exam. When examined, found
issue, just the error completing the form Had the organization filled the form out
correctly, would not have been selected for exam. Form 990 fills important
transparency role, which improved having more accurate information the form.
Henry Kerner asked about the time lag for filing from the election cycle. Lois Lerner
explained that the way the law set up. This like all taxpayers that need extra time complete the forms, they can get extension time so.
Henry Kerner then asked about the penalty part, what happens there problem.
Lois Lerner said that the organization generally compliant, but there was one issue, may issue advisory letter. Henry Kerner asked what advisory letter. Lois
Lerner explained that advisory letter was issued when saw issue, but was
not sufficient result change, but might problem the organization continued. would close the exam issuing the change letter with advisory telling them that were not making change their exempt status tax obligations, but advising
them issues that might affect their exempt status tax obligations the future.
have found that, for the most part, exempt organizations are compliant sector. They
want comply with the law. They also want look good because the public
disclosure the Form 990. For the most part, they fix the problems identify.
Lois Lerner discussed some the issues look at. look compensation issues,
whether the organization paying reasonable compensation. This not easy
calculation. For section 501 (c)(3) organizations there excise tax that imposed the person receiving the excess compensation, not the organization. The managers
who knowingly approved the excess compensation may also subject the excise
tax. might issue advisory about the organizations compensation practices
they had excess compensation. other cases, there might penalties taxes, such the unrelated business income tax. Ultimately, one wants revocation. However, revoke the organizations exempt status, the organization that applied for and
received recognition its exempt status can rely the determination letter
disclosed its activities the application, the revocation prospective. the
organization did not apply, engaged activities that did not disclose its
application, the revocation may retroactive.
Henry Kerner asked whether section 501 (c)(4), (5) (6) organizations never have
apply. Lois Lerner confirmed that they not. Most the applications receive are
section 501 (c)(3) organizations, because those organizations are required the statute apply. Section 501 (c)(3) organizations receive more benefits, such tax-deductible
contributions, and therefore have higher standards meet. The section 501 (c)(3)
organizations use Form 1023 apply, all other section 501 (c) organizations use
Form 1024.
Lois Lerner explained how process applications. All applications received get
screened our most experience determination agents. They quickly look the
application and determine whether the organization has provided sufficient information determine that meets the requirements for exemption. so, send the
determination letter recognizing the organizations exempt status. Approximately 70% the applications last year were screened. This pretty stream-lined process for
organizations that completely filled out the application form and there were questions the face the application. the application cant screened, there second
category may fall into. the organization basically appears okay, but there some
missing information minor change needed (for example, its articles incorporation not have the required purpose dissolution clause). those cases, quickly
request the needed information finish the process. The remaining cases need
fully developed. These cases may have missing information, provide cursory
information about their proposed activities, have inconsistencies, raise legal
questions. The cases must assigned determinations agent that has the
appropriate level experience for the case. addition, for some issues, designate
certain groups specialists for that issue order promote consistency. result,
these cases may wait for while before being assigned agent worked.
have tool our website regarding how long the wait assigned is. are
working improve that tool. Once case has been assigned, the agent reviews the
case and sends letter the organization with development questions. Most cases
are handled that way. Cases involving issues first impression are transferred the
RA office which staffed primarily lawyers who work conjunction with the
lawyers the Chief Counsels office.
The RA office consists the Technical and Guidance functions which handle
exemption applications that present unique issues, private letter ruling and technical
advice requests, congressional correspondence and working with Counsel and
Treasury guidance projects. They also provide support and technical advice the
CEO, Examinations and Determinations functions. They work closely with Counsel
Elise Bean asked the section 501 (c)(4) issue has exploded. Nikole Flax said was
fair say has taken lot time. Lois Lerner said that the last year felt like lot.
Elise Bean said they were trying get feel for the size the issue, they expect fairly small size. She said she was glad are doing the self-declarers
questionnaire. Lois Lerner explained that the 1.5 million organizations were those filing
annual Forms 990 with us. Most those organizations are section 501 (c)(3). With
certain exceptions, all exempt organizations have file annually with us, either the
Form 990, the Form 990-EZ, the Form 990-N. Elise Bean asked how many were
section 501 (c)(4) organizations. Lois Lerner said she did not have that number, but
could get it. She explained that receive approximately 60,000 applications every
year. Henry Kerner asked how many organizations have fallen off the list. Lois Lerner
said that the enactment PPA provided the first time for get sense for how
many fall off. far, approximately 500,000 organizations have had their exempt status
automatically revoked for failure file for three years.
Stephanie Hall asked how know about organizations that dont apply and dont
file. Lois Lerner explained that have systemic way knowing, but someone may
refer the organization. the organization has been holding itself out exempt but not
filing Forms 990 and then files application, will auto revoke the organization. Last
year, addition the 60,000 applications generally receive, also received
additional 20,000 applications seeking reinstatement. That was requirement the
law, they were auto-revoked, they had apply for recognition going forward.
Stephanie Hall asked assessed taxes going back. Lois Lerner explained that the
organizations may request retroactive reinstatement. had some transition relief
the first year and provided lower user fee for small organizations seeking
reinstatement. Elise Bean asked when the first year was. Lois Lerner told her was
2010. Elise asked for ballpark percentage section 501 (c)(4) organizations. Lois
Lerner said that SOl has that information and would get for them. Nikole Flax said could get several years worth information. Lois Lerner pointed out that not all
section 501 (c)(4) organizations are involved political campaign activity.
Elise Bean said they were interested the section 501 (c)(4) organizations that reported
independent expenditures the FEC. She asked had any arrangements with the
FEC where got information about section 501 (c)(4) organizations reporting
independent expenditures. Lois Lerner asked whether the FEC would know whether
organization was section 501 (c)(4) organization. Laura Stuber said that the
organization would have FEC number. Lois Lerner said that she did not know the
FEC required organizations identify themselves section 501 (c)(4) organizations.
Elise Bean asked the FEC were required identify section 501 (c)(4), (5) and (6)
organizations, would the IRS able use that information the FEC database. Lois
Lerner said that there was still timing issue with respect the Form 990 filing. Elise
Bean said that the IRS wanted find organizations monitor, would this information helpful. Lois Lerner said that the organizations were required report the
Form 990 what they are spending. Laura Stuber said that sometimes comparing the
2010 FEC filings the 2010 IRS filings revealed differences. Lois Lerner explained
that even when comparing the same time period, there still might differences. For
example, the FEC electioneering communications rules rely bright line test while
the IRS looks all the facts and circumstances. Elise Bean asked whether would useful have the FEC identify section 501 (c)(4), (5) and (6) organizations
making independent expenditures and the amount those expenditures. Nikole Flax
said there was still timing issue. Even the organization was spending lots money political campaign activity, would not know what else the organization was
spending money. These organizations may engage political campaign activity
without jeopardizing their exemption, but have look their activities for the entire
year. would not know real time whether this was issue. Lois Lerner said that
any information that have useful, just want manage expectations about the
use the information. Elise Bean asked whether could ask the FEC add
something. Nikole Flax said that are open talking them, but that decision rests
with them. With respect the differences what was reported the IRS and the
FEC, Lois Lerner expressed concerns about how the research was done. Henry Kerner
asked that was because the different definitions. Lois Lerner said that was also
due the different types information. While section 501 (c) organizations would
report their independent expenditures the FEC, they make contributions political
committees, the political committee that reports the information the FEC. Both
types expenditures would need reported the IRS. Nikole Flax said there was
not clean match-up for the information. Elise Bean said that could good place start. Lois Lerner said that always useful have information.
Elise Bean asked what percentage section 501 (c)(4) organizations did file
Form 1024. Lois Lerner said that significant number section 501 (c)(4)
organizations apply for recognition One the questions are asking the
self-declarers questionnaire why those organizations that not apply choose not
JW1559-041151 so. Elise Bean asked for ballpark how many section 501 (c)(4) organizations file
Form 1024 and what percentage file Form 990s. Lois Lerner said that anyone not
compliant after three years automatically revoked. Nan Marks noted that
organizations can attempt hide. Lois Lerner said that one our projects looking
skip filers organizations that file least once every three years, but not every year.
Stephanie Hall asked had noticed any difference the desire compliant
section 501 (c)(3) organizations versus other section 501 (c) organizations, since
section 501 (c)(3) organizations receive more benefits. Lois Lerner noted that most
our enforcement the section 501 (c)(3) area, but when look other
section 501 (c) organizations, also see desire compliant with the tax rules.
Laura Stuber asked about the IRS staff focused political campaign activity. Are there
certain staff who work these issues? Lois Lerner said that there are designated folks
looking political campaign issues the Determinations function. provided
training these folks and they work with technical experts the office. Many
cases are also coordinated with Counsel. The application process paper
representation what are the organizations current plans for its future activities. Once organization has been recognized exempt, could change its activities and report
that change the Form 990. have provided training political campaign issues the RA function, both the Determinations staff and the staff the office, and
the Examination function. addition the self-declarers project, are also looking
referrals alleging political campaign activity and are identifying potential indicators
political campaign activity the Form 990 that are testing. Exam agents that work these projects were trained. For any project, the technical experts put together
training the issue.
Laura Stuber asked about the 643 examinations section 501 (c)(4) organizations that identified our response. those 643, there were that reported using PIC
codes that political campaign intervention was issue the exam. our response, explained the limitations the PIC codes and said that would have
manual review for more information. When the manual review was requested, the IRS
declined so. Nikole Flax reiterated what told them our letter. Lois Lerner
said that the PIC code could indicate they looked the issue, but the determination
could that the issue was not present. For example, there may have been
allegation political campaign activity, but determined that the organization did not
intervene. Elise Bean said that less than the cases, identified political
activity issue, using the cases ceiling. Nikole Flax said that the was
not necessarily ceiling. Nan Marks explained that the agents identify the most
important issues the case when choosing the PIC codes. There could cases
where the agent looked political campaign activity issues, but also had UBI,
employment tax other issues that resulted change that were considered more
important. Nevertheless, the number pretty accurate, more likely ceiling.
Elise Bean asked they could say less than cases involved political campaign
activity. Nan Marks said that was probably the right ballpark. Elise Bean asked
had any comment the low number cases involving political campaign activity.
Nikole Flax noted that the numbers would not include the 2010 tax year. Elise Bean
said that these cases would all pre-Citizens United. Nikole Flax said that they should
not look those numbers the current posture. Laura Stuber asked what happened those cases. Lois Lerner referred page the November 23,2012 letter
where discussed the revocation letters. Elise Bean asked what happened the
cases. Lois Lerner explained that track how case closed differently from the PIC
codes. Nan Marks said example would case with political activity,
compensation and unrelated business income issues. The case was closed change
with advisory, but cant relate the closing code the PIC code. Lois Lerner said
that agents would dealing with different issues, would not know without looking
the case files.
After the break, Lois Lerner explained that when open cases where political
campaign activity might issue, look FEC data.
Laura Stuber asked whether was red flag group reapplies under another name.
Lois Lerner said that ask the Form 1023 and Form 1024 whether they had
different name had applied before. Laura Stuber said looked bad. Lois Lerner said
that without knowing the facts, she couldnt say. There may legitimate reasons
change the name. For example, there bad press about person associated with
organization that taints the public perception the organization, the organization may
decide end its relationship with the person and change its name. have seen
some auto-revoked organizations that try join group ruling rather than applying for
reinstatement, but find them.
Elise Bean asked about the interpretation primarily allowing 49% other
activities. Where did people get that? Judith Kindell explained that when GCMs were
released the public, one was released with some supporting background memos.
one those memos, there was statement that while the 51/49 was not supportable
for section 501 (c)(3), was reasonable interpretation the section 501 (c)(4)
regulations. Elise Bean asked for copy that GCM. Laura Stuber asked the GCM
was released around the time that the IRS was considering change the regulations.
Nan Marks explained that GCMs used internal documents. Tax Analysts brought case against the IRS seeking disclosure these internal documents which they won the early 1980s.
Elise Bean said that the primarily issue, everyone wants bright line rule. Why
there bright line guidance? Nikole Flax said that one issue 49% what have facts and circumstances test. Lois Lerner said the real question what the political
campaign activity. Susan Brown used example organization that supports the
cherry trees that has lot volunteers doing work with the cherry trees, but very few
expenditures, most all which are for political campaign activity. Under the facts
and circumstances test, can look all the volunteer activity and determine that
this good organization. Under pure expenditure test, that organization would have problem. Elise Bean agreed that looking volunteer activity important, but why not percentage test. Laura Stuber noted that section 501 (c)(3) has 20% test. Susan
Brown explained that section 501 (c)(3) organizations can not intervene political
campaigns, but can engage limited amount lobbying. That was originally under
facts and circumstances test. Congress enacted section 501 (h) allow
section 501 (c)(30 organizations elect subject pure expenditure test. With
respect the regulations, Janine Cook pointed out that have look the law
whole and that the section 501 (c)(3) regulations have the same language. Lois Lerner
said that they have careful about unintended consequences.
Elise Bean asked whether would make sense have similar rule for
section 501 (c)(4). Susan Brown asked clarify whether would for all non-exempt
activity. Elise Bean said that would rule for political campaign activity. Lois
Lerner said that under existing rules have look all non-social welfare activity.
Elise Bean asked about the primary test for section 527 organizations. Judith Kindell
explained that, while the test for tax exempt status whether the organization
organized and operated primarily accept contributions and make expenditures for
section 527 exempt function, the way taxed further limits the amount non-political
campaign activity can do. The statute excludes from taxable income certain types
income, provided they are segregated for section 527 purposes. section 527
organization has one fund and makes more than insubstantial non-section 527
expenditures from that fund, longer segregated and all the income that fund taxable income. section 527 organization has more than one fund and makes
more than insubstantial non-section 527 expenditures from one the funds, that fund longer segregated and the income that fund taxable, but the other funds remain
segregated the income those funds may excluded from taxable income.
both cases, the organization still may primarily engaged exempt function activities
and therefore still treated tax-exempt section 527 organization.
Elise Bean said that organization was primarily engaged political campaign
activities, had choice but treated section 527 organization. Susan
Brown said that could taxable section 527 organization. Elise Bean said that
section 501 (c)(4) organization had 70% its expenditures political campaigns and
had volunteer activity, clearly wouldnt qualify for section 501 (c)(4) and shouldnt section 527 organization. Lois Lerner said that meets the requirements for
section 527 would, but would not necessarily tax-exempt. Judith Kindell
explained that certain section 527 organizations were required notify the IRS
treated tax-exempt. they did not, they were taxable organizations and all their
income was included gross income and they could only deduct those expenses that
were directly connected earning the taxable income. Therefore, they could deduct
the fundraising expenses generate their contribution income, but could not deduct the
amounts spent their political campaign activity. Lois Lerner said that when see
that organization not qualified under the code section has applied under, tell
them they are taxable. Sometimes work with the organization get them the
right code section. Elise Bean said that want encourage them section 527
organizations, why dont take the step for section 501 (c)(4) organizations that fail
and tell them they are section 527 organization. Judith Kindell noted that taxable
section 527 organizations are not required disclose their donors. Lois Lerner said
that based her days the FEC, the organization made mistakes, the money was
already gone. Elise Bean said they were interested preserving the integrity the tax
code. The organization should not able say just corporation, that
section 527 organization. Lois Lerner said they should consider the impact the
legislation. She expects organizations will just rack enormous expenses with
money left. Henry Kerner asked how get the abuse organizations claiming
section 501 (c)(4) but designed primarily political. Lois Lerner said the system
works, but not real time. Henry Kerner noted that these organizations dont disclose
donors. Lois Lerner said that they dont meet the requirements, can come and
revoke, but doesnt happen timely. Nan Marks said the concern that the
organizations engaging this activity dont disclose donors, then the system doesnt
work. Henry Kerner said that maybe the solution audit many that financially
ruinous. Nikole noted that have budget constraints. Elise Bean suggested using the
list organizations that made independent expenditures. Lois Lerner said that her
job oversee all, not just political campaign activity. Lois Lerner said that she does
have other tools. When issue compliance check questionnaires, are very
transparent about and post the questionnaire our website.
Elise Bean asked about section 527 disclosures. Lois Lerner explained that these were the IRS website searchable database. Susan Brown said that under the
primarily test, organization could fail qualify section 501 (c)(3) without
automatically being section 527. Henry Kerner asked whether taxable corporation
could deduct business expenses. Lois Lerner noted that she never saw rule that
stopped the money from flowing politics, just moved another venue.
Elise Bean asked how determined what political activity and about the law,
regulations and revenue rulings. Nan Marks said that revenue rulings are the opinion
the IRS how the law applies set facts. They are precedential, but given
less preference. respect revenue rulings, even made mistake. How
revenue rulings have changed over time, but the recent practice fairly long standing
for IRS, Counsel and Treasury work together with sign off from all three offices from
senior levels. Elise Bean asked about exam guidance and educational material. Lois
Lerner said that generally this not precedential, but judge wants use it, the
judge will. Nan Marks said that regulations are the drafted product Chief Counsel,
but they are Treasury regulations and all three offices (IRS, Counsel, Treasury) work
them and they are cleared through all three offices. Regulations get deference.
Elise Bean said that the facts and circumstances test not the regulations, just
revenue rulings. Where did the facts and circumstances test come from. Nikole Flax
said that absent bright line, generally use facts and circumstances test. Nan
Marks said this general rule prevalent tax law. Elise Bean asked there
general regulation providing for the facts and circumstances test. She said that
Senator Levin thinks there should more bright line tests. Janine Cook noted that
the section 501 (c)(3) regulations states that all facts and circumstances are
considered. Lois Lerner said that the problem with bright line tests that there are
always exceptions. Elise Bean said that Senator Levin worked BeRA which
provided bright line test for electioneering communications. Nan Marks suggested
step back and look the generic issue. When you have line drawing the statutory
level, follow those lines. you have fuzzy statute, some clarification desirable,
but what extent appropriate draw bright lines.
Elise Bean said that Senator Levin believes more regulations are needed, not revenue
rulings. She said that the regulations should provide you make independent
expenditure, that political campaign activity. you give money candidate, that
political campaign activity. The regulations should provide some bright line rules. Lois
Lerner said that you put out regulation that says these items are in, those are the
only items that are in. With revenue ruling, can say here are the facts and here how think about it. Elise Bean said that are dealing with regulation that
really old and two revenue rulings that are really old. When the issue politics, the IRS
gets creamed matter what.