[EL] query on 501c4 IEs and the FEC PAC rules

[Rick Hasen]

I understand that in this election cycle and the last (since CU) 501c4 
organizations (which did not qualify as MCFL/QNC corporations) have been 
running not just electioneering communications ads, but also making 
independent expenditures (including express advocacy).
How do 501c4s which are making IEs argue that they need not register 
with the FEC as a political action committee?  Are they arguing that 
electioneering is not their major purpose (along the lines of how they 
argue to the IRS that election related activity is not the "primary 
activity" for tax purposes)?

Thanks.
Rick
-- 
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072 - office
949.824.0495 - fax
rhasen at law.uci.edu
http://law.uci.edu/faculty/page1_r_hasen.html
http://electionlawblog.org