[EL] Technology to facilitate compliance
BZall at aol.com
BZall at aol.com
Mon Aug 15 10:34:40 PDT 2011
In a message dated 8/15/2011 12:36:41 P.M. Eastern Daylight Time,
tpotter at capdale.com writes:
Individual activity is of course constitutionally important and vital to
our democratic system, as is small group activity. My repeated point is that
such activity can be done at the federal level (which is the level I was
discussing) without lawyers or accountants. The FEC website provides forms
and detailed information and advice. This is possible for individuals and
small groups--as opposed to more complicated political actors----precisely
because they are small and their issues relatively simple.
Sigh. If only that were true.
Let's take a simple example: Mom and Pop Bo Peep become concerned about S.
666, new legislation promoting increased shearing. Their Senator, Sen.
Potter, chairs the Senate Sheep Shearing and Fleecing Committee, which has
scheduled a markup on S.666 next week. The Bo Peeps start a new group: "No
More Clips!" NMC raises enough money to send a couple of rounds of direct
mail.
Since they only have a little money, they decide they'll get their biggest
bang for the buck by sending their message to Sen. Potter's campaign
contributors, a la the recent Target campaign. "Tell Sen. Potter NO on S. 666!"
is their text. Their campaign meets the IRS's definition of issue advocacy
under Rev. Rul. 2006-4, which, of course, they've never heard of and
probably couldn't find. Grassroots lobbying, which is what this message would be
is non-deductible, but they have no clue about that or about the requirement
that their solicitations and donor acknowledgements must contain a
disclaimer about non-deductibility (or I suppose they could just pay the "proxy
tax" on lobbying communications). Nor do they know that their message is a
grassroots communication under LDA rules, although the ABA AdLaw Section
wants to regulate grassroots lobbying under the LDA, which might ensnare the Bo
Peeps in yet another regulatory filing. But leaving aside all those taxes
and regulatory filings just to say they don't want to be sheared, let's
return to their central plan and the FEC.
NMC uses FEC contributor data to contact Sen. Potter's biggest donors.
After all, Sen. Potter has said "Individual activity is of course
constitutionally important and vital to our democratic system, as is small group
activity." And they watched the FEC instructional video about the use of campaign
contributor information, in which the FEC says that "Complete and accurate
disclosure of the sources and amounts of funds used to finance federal
elections is the cornerstone of America's campaign finance law."
_http://www.youtube.com/watch?v=GIEsyfCKZEA_ (http://www.youtube.com/watch?v=GIEsyfCKZEA)
(at 6:28). And they understand the Supreme Court's decision in Doe v. Reed
to have said that such reports, if they are deemed to have political
significance, are public information. And they have read lots of places that
Citizens United promoted disclosure. "We like disclosure," the Bo Peeps say.
"We learn who gave money so we can talk to them about it."
The first time they use the disclosed information for their "No on S. 666"
message, there's no problem. But NMC uses it a second time, and BOOM, Sen.
Potter's office calls them. He says they are harassing his donors. He tells
the Bo Peeps that the FEC has ruled that they can use the list once for a
political message, but a second time is forbidden by the FEC under AO
2003-4 (Tobacco Free Kids). He also says they are violating his campaign's
financial rights in its list under FEC v Int'l Funding Institute, Inc., 969
F.2d 1110 (DC Cir. 1992) (en banc) (solicitation provision constitutional
because it affects political committees' economic interests in their lists)
(RBG concurring that Congress's choice was "sensible"). He neglects to point
out the conflicting 2nd Circuit decision in FEC v Political Contributions
Data, Inc., 943 F.2d 190 (2d Cir. 1991)(not considering "troubling First
Amendment questions raised by the Commission's regulations"). The Bo Peeps
protest that they didn't know; that they weren't soliciting memberships or
using the names for a commercial purpose. Sen. Potter laughs and says,
"Nonsense, you could have looked up the Advisory Opinion on the FEC website. It's
easy and simple."
Threatened with prison time or fines for using disclosed data, the Bo Peeps
close NMC, retreat to the barn, bleat piteously as they are sheared (at
least metaphorically), and emerge bleeding from the process.
If you are a simple American, you read the papers, you believe what people
tell you, you think you can use the newly-touted disclosure mechanisms to
do what people have always done: petition the government for redress of
grievances. Even if you read the FEC's own instructional data and publications,
view their videos, and talk to people in the business, you have no clue
that you can't actually USE the disclosed information for political purposes
(at least not more than once). You think that disclosure's a good thing; at
least that's what you're told.
In reality, if you learn about the law (ALL the laws) you find that you are
but a sheep led to . . . oh, never mind.
Barnaby Zall
Of Counsel
Weinberg, Jacobs & Tolani, LLP
11300 Rockville Pike, Suite 1200
Rockville, MD 20852
301-231-6943 (direct dial)
_www.wjlaw.com_ (http://www.wj/)
bzall at aol.com
_____________________________________________________________
U.S. Treasury Circular 230 Notice
Any U.S. federal tax advice included in this communication (including
any attachments) was not intended or written to be used, and cannot be
used, for the purpose of (i) avoiding U.S. federal tax-related penalties
or (ii) promoting, marketing or recommending to another party any
tax-related matter addressed herein.
_____________________________________________________________
Confidentiality
The information contained in this communication may be confidential, is
intended only for the use of the recipient named above, and may be legally
privileged. It is not intended as legal advice, and may not be relied upon
or used as legal advice. Nor does this communication establish an attorney
client relationship between us. If the reader of this message is not the
intended recipient, you are hereby notified that any dissemination,
distribution, or copying of this communication, or any of its contents, is
strictly prohibited. If you have received this communication in error,
please re-send this communication to the sender and delete the original
message and any copy of it from your computer system. Thank you.
______________________________________________________________
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Mon 8/15/2011 10:33 AM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
Your position, as I understand it, has been that citizens are represented
through large organizations, such as the NRA, NARAL Pro-Choice, unions, and
large professional organizations. (We will not unduly harp on the fact
that for years many members of the reform community has demanded more
restrictions on PACs, at different times expressing a desire to abolish them).
Similarly, you have suggested that large corporations can afford large PACs.
And you have suggested that small corporations that have a PAC do so solely
for lobbying, ignoring the real point that a) virtually no such companies
have PACs because the combination of compliance and the restrictions on
fundraising make them impractical, and b) to the extent they are practicable,
they are only such if used for the limited purpose of supplementing lobbying,
rather than having a serious impact on political debate.
The point that Jim, Larry, I and others have been raising is that the
rules are a real hardship on small, often-spontaneous, grassroots activity.
Your response, and Doug's has been that this type of activity really isn't
very important. People who can't afford to hire Caplan-Drysdale aren't likely
to raise much money or have much influence anyway. As Doug suggested, maybe
if they can't handle the compliance, they should find other ways to
participate. This does have some truth to it, but it is not a normative position
I find inspiring and it is a position that reinforces the pull of large
entities and discourages, indeed is even dismissive of, the political
activities of citizens in everyday life.
The presence of large organizations exercising political influence simply
does not do away with the question of the effect of these laws on small
organizations, local party committees, small, volunteer-based campaigns, and
spontaneous citizen-directed and organized activites. Indeed, the dominance
of large organizations may reflect in some respects the difficulty of
organic, grassroots participation under the law.
Challenged to come forth with "proof" that more activity that might be
going on if there weren't these laws in place (not an easy task, to be sure,
since no one can no for sure) and the cost of compliance, we have presented
evidence of the cost of the compliance and evidence from our own
experiences that many people are discouraged from participation by these laws. Your
response, which amounts to "hey, stop complaining, they've got the NRA" is,
I take it, a concession of the point we originally raised, by you who have
insisted on calling us "plutocrats."
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Mon 8/15/2011 9:43 AM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
Brad:
I have said expressly the opposite. I assume others can read, and am
ending this thread.
Trevor
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Mon 8/15/2011 9:25 AM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
It appears to me that you are conceding that the rules have largely
stomped out small scale grassroots political activity.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Mon 8/15/2011 9:24 AM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
All of the examples I gave were of non-connected, non business PACS. That
is because "average citizens" have historically organized around causes and
issues, such as guns, life/choice, ERA, retirement, etc. one could extend
this to professions--lawyers, doctors, bankers, nurses, and the
traditionally big one--laborers, usually represented for economic purposes by unions.
And Brad and others were claiming that these "average citizens" were
somehow advantaged by Citizens United license to corporations.
None of that has anything to do with Brad's example: a small company
employing 65 people, of whom maybe 10 or 20 are in the "restricted class" and
thus solicitable. In my experience, such companies have a PAC for only one
reason--as a lobbying tool. Their lobbyist has told them he/she needs to take
a PAC check to Washington events to spend time with Members of Congress. I
know of companies that do this--and the compliance costs are minimal, as
the PAC by definition has only a handful of donors and does not make many
contributions. An administrative assistant fills out the reports. For a small
company, of that is needed if for an executive to walk around the halls
and personally solicit the handful of people, with virtually no overhead.
To re-state my earlier point, the larger the operation, the more
complicated compliance becomes. Payroll deduction, professional fundraisers,
four-color solicitation materials, an expensive "charitable match" program --they
all add to the cost. Of course, those are not truly COMPLIANCE
expenditures--those are business expenses voluntarily incurred by the company because
they want a larger PAC to have more political clout--read lobbying power.
That may well be a rational business decision, but only by bootstrapping does
it become a regulatory burden.
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Mon 8/15/2011 8:37 AM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
The point is, a small PAC of ordinary citizens, or a small business, a)
can't pay those admin costs from the corporate treasury, and can't afford
them if they can, and b) still has to incur substantial costs in raising funds
in accordance with the rules - costs that are made much higher by the
rules (this is part of what SpeechNow.org v. FEC was about).
Realistically, for example, there is no way a small business employing,
say, 65 people, can afford to operate a PAC given the compliance and
administrative costs (remembering that the administrative costs are almost all
"compliance costs" in that they are substantially the result of the
regulations), and that such a company is likely to have a small number of people it
can even solicit. So the vaunted PAC option becomes a big money game. And the
regulations cut off alternatives for more ordinary citizens and more
grassroots activity.
I'm not quite sure why you seem to think that the operation of big money
PACs mean that PACs are a viable alternative for people without big money.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Sun 8/14/2011 10:21 PM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
That's what I expected. And solicitation costs include outside fundraising
consultants, PLUS for most Fortune 500 companies the costs of the amazing
"matching gift" program, in which the FEC has allowed companies to offer
their PAC donors a dollar for dollar match of contributions to their favorite
charities. I don't dispute it is possible to spend a million dollars a
year on a corporate Pac--but that is a cadillac of a PAC...and every penny of
that million dollars is from the corporate treasury, not from PAC funds.
Trevor
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Sun 8/14/2011 10:10 PM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
That's the total administrative costs, for example, including solicitation
costs, which are increased by the rules and regulations, of course,
including the limits on the size of contributions.
Ansolabehere, de Figueiredo & Snyder, Why is there so little money in
U.S. politics?, 17 J. Econ. Perspectives 105, 109.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Sun 8/14/2011 9:56 PM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
Brad:
Is there a citeation to that figure? And does it include solicitation
costs (or matching giving)? Based on my experience, that is farb more than an
accountant and occasional legal questions...
Trevor Potter
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Smith,
Brad
Sent: Sun 8/14/2011 8:29 PM
To: Volokh, Eugene; law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
By the way, to give some sense of things, in recent years the typical
Fortune 500 company PAC has spent approximately $1 million per year on
administration, or roughly half of its total take. I think we can safely assume
that for smaller PACs, the administrative costs are an even higher percentage
of the amount raised and spent.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Smith,
Brad
Sent: Sun 8/14/2011 8:24 PM
To: Volokh, Eugene; law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
Well, first it is the forms. It's not that they are computerized or not -
it's that they exist. Filling in the data is not that hard - that's not the
problem. Rather, it is figuring out where the data go, and keeping track
of the underlying numbers. The forms are typically quite complex, and we
forget that most people are not used to dealing with forms and legaleze
instructions. (Some might recall the John Stoessel episode in which he asked
"reform" spokespersons to fill out forms, which most couldn't do; a couple
studies, one, I believe, by Jeffrey Milyo, found that people couldn't complete
the forms correctly even with direct monetary incentives to do so. If you
want to try, go to the FEC website, pull up some basic forms, and see how
you do). It is very difficult for an amatuer to know how to classify various
expenditures and income, for example, and especially what to do with even
minor asset sales and the like. The laws also make the book-keeping for
routine old time fundraising - selling ice cream at the county fair, passing
the hat at a rally, speech, or gathering; selling some t-shirts, etc -
virtually impossible. This points up the second problem, knowing and complying
with the underlying rules. Third, it is the formal accounting systems that
must be established to comply with the law. Fourth, it is the threat of legal
liability and fines for mistakes. The more heavily reliant a campaign is
on volunteers, the more likely it is that one or more of those volunteers
will make mistakes subjecting the campaign to liability. Thus volunteers are
in some cases outright discouraged, and in others kept on a tight leash -
they can lick envelopes, for example, but are discouraged or prohibited from
asking for funds or arranging events.
I estimate overall that a very small, ongoing campaign that wants to be
relieved of these duties should budget $3000 to $5000 a month for
professional fees. For many small campaigns, even that amount will be far too low. Add
in the fear of violations, and that stomps out a lot of activity. Of
course, a single complaint can raise that cost dramatically, even if the
complaint ultimately fails to even meet the relatively low "reason to believe"
standard. An initial response to a complaint is typically $5000 to $10,000.
Having seen the operations from inside, I would not advise a campaign to
responde without counsel. Obviously, a complaint that leads to a full
investigation can cost tens or even hundreds of thousands of dollars, even if the
complaint is dismissed before trial.
Potential fines for violations are typically substantial for small
violators. For example, a campaign with $2500 in expenses that fails to file a
report faces a $250 fine for a first time violation. If that is an "election
sensitive report," however, they are looking at a $550 fine for a first time
offense. These are fines that go through the FEC's "administrative fines"
system. The minimum fine for anything that must go through regular
enforcement is historically $1000. The statute generally authorizes fines for
unintentional violations of up to $5000 or the amount in question, whichever is
larger. The FEC calculates the amount in question so as to raise liability:
e.g., before Citizens United, if a small business spent $1.32 to mail
three solicitations from the company CEO, and because of that raised $6000, the
FEC views the amount of the violation as $6000, not the $1.32 actually
spent. PAC treasurers are personally liable for fines if the PAC cannot (or
will not) pay it.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Volokh,
Eugene
Sent: Sun 8/14/2011 7:41 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
So - and again a naïve question - what, practically is the burden of
compliance (especially as to disclosure) for small campaigns? I'm not doubting
that there is such a burden; I just want a better sense of what it is, and
whether it can be mitigated.
Eugene
From: law-election-bounces at department-lists.uci.edu
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Smith, Brad
Sent: Sunday, August 14, 2011 4:15 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
The automation rule is the norm at the FEC, which provides free software,
and in many if not most states. Many small campaigns, however, still have
difficulties with using the software.
The technical filling of data, however, is not the real problem, though it
does add to the costs and fears that people have. And believe me, people
do have fears.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Volokh,
Eugene
Sent: Sun 8/14/2011 5:52 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
I agree entirely that the government should provide the software -- which
will often be as simple as a Web page (with supporting software) hosted on
the jurisdiction's election commission Web site, or perhaps a spreadsheet
template that people could fill in and that the Web page could accept for
batch uploads, plus perhaps some software to provide automatic schedule
reminder e-mails to everyone who signs up. But this is not rocket science; this
would be a simple application of well-understood, routinely used
technology.
Indeed, I would think there should be a general principle, whether enacted
in statute or just as a strongly accepted guideline -- let's call it the
Automation Rule: Every disclosure and reporting regulation imposed by
election law must be accompanied with government-provided software, and that
proper use of such software would fully discharge the user's legal obligations
under the jurisdiction's election law. Naturally, the software also has to
be made easy to use, and it's hard to come up with a purely legal rule to
make sure that it is easy enough to use. But it seems to me that if the
Automation Rule isn't an existing norm already, it should be.
Eugene
> -----Original Message-----
> From: law-election-bounces at department-lists.uci.edu [mailto:law-election-
> bounces at department-lists.uci.edu] On Behalf Of Larry Levine
> Sent: Sunday, August 14, 2011 12:23 PM
> To: 'Kathay Feng'; Volokh, Eugene; law-election-bounces at department-
> lists.uci.edu; law-election at department-lists.uci.edu
> Subject: Re: [EL] Check out Study shows who breaks campaign laws-
> ThePuebloChieftai...
>
> Transaction costs are just a very small part of the matter. It is the
rules
> about what needs to be reported and upon what schedule that creates the
> traps. These rules often differ from jurisdiction to jurisdiction and
change
> from election cycle to election cycle within the same jurisdiction. If
the
> government is going to require automated (electronic) filing of
> contributions and expenditures, then the government should either provide
> the software and hardware needed to comply free of charge, or allow those
> costs to fall beyond the limits of spending on a campaign.
> The difficulty with so much of what we enact in the way of reporting
reforms
> is that they may apply well to big statewide races or even to legislative
> races. But when you come down to a city council campaign in a town of
just a
> few thousand people, or in a very small school district those
requirements
> become burdensome.
> Larry
>
> -----Original Message-----
> From: law-election-bounces at department-lists.uci.edu
> [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of
Kathay
> Feng
> Sent: Sunday, August 14, 2011 11:58 AM
> To: Volokh, Eugene; law-election-bounces at department-lists.uci.edu;
> law-election at department-lists.uci.edu
> Subject: Re: [EL] Check out Study shows who breaks campaign laws-
> ThePuebloChieftai...
>
> Automation is certainly a practical solution that would help. In
California,
> we had a bi- and non-partisan group of reformers, the regulated
community,
> citizen groups and others that all agreed that greater automation would
help
> with disclosure, and significantly lower transaction costs for both
> campaigns and the government. The idea is still stuck in the mud,
though.
> Sent via BlackBerry by AT&T
>
> -----Original Message-----
> From: "Volokh, Eugene" <VOLOKH at law.ucla.edu>
> Sender: law-election-bounces at department-lists.uci.edu
> Date: Sun, 14 Aug 2011 10:41:53
> To:
>
law-election at department-lists.uci.edu<law-election at department-lists.uci.edu>
> Subject: Re: [EL] Check out Study shows who breaks campaign laws
> - ThePuebloChieftai...
>
> A naïve question: Could some of these problems -- at least to
> filing -- be relieved with automation (and might they already be so
> relieved), especially with automation that the jurisdiction is willing to
> certify as sufficient? For instance, I certainly sympathize with
concerns
> about the burden of reporting contributions and expenditures, but what
if
> State X, when it enacts some such disclosure restrictions, provides that
the
> obligation is discharged if a campaign worker goes to a particular Web
site
> and accurately enters all the data he's asked to enter? Likewise, I
take it
> that whatever software is used to gather credit card donations via the
Web
> presumably already creates a data file that can just be sent to the
election
> authorities to discharge the disclosure obligations. Or am I missing
> something big here?
>
> Eugene
>
> > On Sun, Aug 14, 2011 at 1:05 PM, Larry Levine
<larrylevine at earthlink.net>
> wrote:
> > > You've touched a nerve. We have "reformed" our way into a time when
> > > one cannot run an election campaign of any size, or a PAC, or
> > > conduct activities of a state or local political party or club
> > > without the cost of a professional treasurer and an attorney on
> > > retainer. At the same time we are placing limits on the amounts of
> > > contributions and the permissible expenditures in campaign without
> > > allowing for these "overhead" items to come from a separate account.
> > > Gone is the day when a volunteer can be the treasurer of a campaign
> > > for a friend if the campaign is of any consequential size. On top of
> > > that, we have created a thicket of regulations and requirements that
> > > differ from state to state and from jurisdiction to jurisdiction
> > > within a state, thus making it virtually impossible for a campaign
> > > and/or a candidate to avoid violations without the services of an
> > > elections attorney who is watching over every facet of the campaign.
> > > And all in aide of stamping out the perception of corruption. Tell
> > > me, is the perception any less now than when we started the "reforms"
> some 40 years ago?
> > >
> > > Larry
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> http://department-lists.uci.edu/mailman/listinfo/law-election
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> http://department-lists.uci.edu/mailman/listinfo/law-election
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> http://department-lists.uci.edu/mailman/listinfo/law-election
_______________________________________________
Law-election mailing list
Law-election at department-lists.uci.edu
http://department-lists.uci.edu/mailman/listinfo/law-election
<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
To ensure compliance with requirements imposed by the IRS,
we inform you that, unless specifically indicated otherwise,
any tax advice contained in this communication (including any
attachments) was not intended or written to be used, and
cannot be used, for the purpose of (i) avoiding tax-related
penalties under the Internal Revenue Code, or (ii) promoting,
marketing, or recommending to another party any tax-related
matter addressed herein.
This message is for the use of the intended recipient only. It is
from a law firm and may contain information that is privileged and
confidential. If you are not the intended recipient any disclosure,
copying, future distribution, or use of this communication is
prohibited. If you have received this communication in error, please
advise us by return e-mail, or if you have received this communication
by fax advise us by telephone and delete/destroy the document.
<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
To ensure compliance with requirements imposed by the IRS,
we inform you that, unless specifically indicated otherwise,
any tax advice contained in this communication (including any
attachments) was not intended or written to be used, and
cannot be used, for the purpose of (i) avoiding tax-related
penalties under the Internal Revenue Code, or (ii) promoting,
marketing, or recommending to another party any tax-related
matter addressed herein.
This message is for the use of the intended recipient only. It is
from a law firm and may contain information that is privileged and
confidential. If you are not the intended recipient any disclosure,
copying, future distribution, or use of this communication is
prohibited. If you have received this communication in error, please
advise us by return e-mail, or if you have received this communication
by fax advise us by telephone and delete/destroy the document.
<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
To ensure compliance with requirements imposed by the IRS,
we inform you that, unless specifically indicated otherwise,
any tax advice contained in this communication (including any
attachments) was not intended or written to be used, and
cannot be used, for the purpose of (i) avoiding tax-related
penalties under the Internal Revenue Code, or (ii) promoting,
marketing, or recommending to another party any tax-related
matter addressed herein.
This message is for the use of the intended recipient only. It is
from a law firm and may contain information that is privileged and
confidential. If you are not the intended recipient any disclosure,
copying, future distribution, or use of this communication is
prohibited. If you have received this communication in error, please
advise us by return e-mail, or if you have received this communication
by fax advise us by telephone and delete/destroy the document.
<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
To ensure compliance with requirements imposed by the IRS,
we inform you that, unless specifically indicated otherwise,
any tax advice contained in this communication (including any
attachments) was not intended or written to be used, and
cannot be used, for the purpose of (i) avoiding tax-related
penalties under the Internal Revenue Code, or (ii) promoting,
marketing, or recommending to another party any tax-related
matter addressed herein.
This message is for the use of the intended recipient only. It is
from a law firm and may contain information that is privileged and
confidential. If you are not the intended recipient any disclosure,
copying, future distribution, or use of this communication is
prohibited. If you have received this communication in error, please
advise us by return e-mail, or if you have received this communication
by fax advise us by telephone and delete/destroy the document.
<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->
To ensure compliance with requirements imposed by the IRS,
we inform you that, unless specifically indicated otherwise,
any tax advice contained in this communication (including any
attachments) was not intended or written to be used, and
cannot be used, for the purpose of (i) avoiding tax-related
penalties under the Internal Revenue Code, or (ii) promoting,
marketing, or recommending to another party any tax-related
matter addressed herein.
This message is for the use of the intended recipient only. It is
from a law firm and may contain information that is privileged and
confidential. If you are not the intended recipient any disclosure,
copying, future distribution, or use of this communication is
prohibited. If you have received this communication in error, please
advise us by return e-mail, or if you have received this communication
by fax advise us by telephone and delete/destroy the document.
_______________________________________________
Law-election mailing list
Law-election at department-lists.uci.edu
http://department-lists.uci.edu/mailman/listinfo/law-election
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20110815/8293fb62/attachment.html>
View list directory