[EL] BOLOs, TAGs, and Drums

[Smith, Brad]

That raises yet another question: why is the IRS doing this in advance? How can the IRS tell if a group is meeting certain tax criteria if it is just starting? If you form an LLC or an LLP or a Sub-S or a 527 or general corporation or a partnership or a unincorporated association, or file as an individual, the IRS doesn't scrutinize to see if you've picked the right category or are operating properly before you do anything.

When you incorporate a business, or register a car or home, the government doesn't check in advance to see if it thinks you might be planning to commit fraud.

All of this comes about because in Buckley v. Valeo, the Supreme Court, following a long line of precedent, said you can't demand donor and member lists from groups if their major purpose is not campaign activity and they are not under the control of a candidate. In 2000, the campaign finance regulatory advocates figured out a way around this: let's require disclosure as a condition of tax status as 527s, relying on Regan v. Taxation With Representation, which held that the government could place conditions on favorable tax treatment. This is a highly dubious proposition, since it is hard to see how 527s get favorable tax treatment (see Guy Uriel-Charles & Gregg Polsky, Regulating 527 Organizations, 73 Geo. Wash. L. Rev 1000 (2005)) but so far nobody has tried to push a challenge. In any case, this end-run of what Buckley provided is now at the core of the assault political speech, and why it matters at all if groups are c4s or 527s (since it's a non-distinction from the point of government revenue).

Thus, the reformers have quite intentionally brought the IRS into the regulation of political speech, something I would think most people would recognize is even more dangerous than the regulation of political speech by the FEC. It is hard to imagine something less relevant to the IRS's core mission than poring over applications trying to determine the difference between c4s and 527s, and it is a recipe for arbitrariness and intentional or unintentional bias.

That is why people such as Joe and I emphasize that whether or not this was motivated by partisanship, it is a scandal. Trevor and Justin have argued that that matters a lot, and I wouldn't disagree - but it is a scandal either way, and ought to be taken seriously.

Moreover, it is, either way, part of a larger pattern of very disturbing behavior in which high ranking members of our government, abetted by various special interests (most of which operate as c3s and c4s), have worked to create a climate in which opposing view are presented and dangerous and unpatriotic, and suppression of those opposing views is considered a good or even necessary thing.

Very sad.


Bradley A. Smith

Josiah H. Blackmore II/Shirley M. Nault

   Professor of Law

Capital University Law School

303 E. Broad St.

Columbus, OH 43215

614.236.6317

http://law.capital.edu/faculty/bios/bsmith.aspx

________________________________
From: Legal Works of Marc Greidinger [mpoweru4 at gmail.com]
Sent: Thursday, August 08, 2013 12:24 PM
To: 'Trevor Potter'; 'Joe La Rue'; Smith, Brad
Cc: law-election at department-lists.uci.edu
Subject: RE: [EL] BOLOs, TAGs, and Drums

Several years ago, an organization beginning to put together local farmers markets I was on the Board of applied for 501(c)(3) status. It had been specifically encouraged to do this under a Department of Agriculture program designed to promote farmers markets as a boon to local farmers, local economies, and nutrition. The IRS apparently had not gotten the memo from the Department of  Agriculture, and papered the organization to death with hundreds of written interrogatories and requests for production under tight deadlines. We found out that the IRS was also doing this to many other similar farmers market organizations, apparently out of some unknown IRS official’s misguided belief that Farmers’ Market organizations were inherently businesses posing as non-profits.

The IRS’s unofficial attitude toward farmers markets in general caused the Farmer’s Market organization I was involved with to abandon its effort to organize under 501(c)(3), even though, as far as I could tell, the organization was of the kind that 501(c)(3) status was designed to help, and was doing things consistent with public policies promoted by the Department of Agriculture.

These BOLOs and “IRSgate” have always impressed me as similar stupidity to the above, not conspiracy. The Republicans must be getting rather frustrated at this point, having invested so much time and effort into trying to connect the Obama Administration to a juicy scandal – hopefully against the right – c to be foiled by a mundane explanation at every turn. But even in the absence of conspiracy, if we are going to have (c)(4)s involved in issue advocacy, it should not matter what type of organizations the “key words” screening pulls out: any such screening is likely to chill, and will disadvantage someone’s voice which is likely representing an interest, or competing with someone elses. If we are going to maintain the advantages organizations benefit from under (c)(4) there should be no such screening. A more interesting question  is whether in general it makes sense anymore for issue advocacy organizations to enjoy the advantages available to them under (c)(4), and whether issue advocacy orgs posing as (c)(3)s should continue to benefit from tax advantages with so little critical IRS scrutiny.



Marc Greidinger
Attorney at Law
https://www.facebook.com/GreidingerLegalWorks?ref=br_tf
(703) 323-4661

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Trevor Potter
Sent: Thursday, August 08, 2013 10:40 AM
To: Joe La Rue; Smith, Brad
Cc: law-election at department-lists.uci.edu
Subject: Re: [EL] BOLOs, TAGs, and Drums

The scandal was supposed to be that IRS employees targeted conservative groups because of their political beliefs. That is in fact a scandalous accusation for what is supposed to be a non-partisan agency strictly above politics and which needs the trust of the American people to function.

Joe LaRue says:

“And I continue to beat my drum and say: it doesn't matter whether it was all conservative groups, or all progressive ones, or a mixture of each that was targetted.”

I disagree. If it turns out that the IRS challenged both progressive and conservative groups, delayed their c4 applications, put them in dead-end piles, audited them after complaints were received, and general poorly managed their status, then we have a completely different issue. If this turns out to be the case—whether through “BOLOS” or “emergent issues”—then the question becomes why did this happen. Was it from mismanagement, understaffing, poor training or leadership, or an  inability of the IRS to address the status of highly political c4s under current rules and in the midst of a partisan battleground where members of Congress of both parties are regularly attacking the agency for favoring the other party? In other words, have they just frozen in the midst of battle? That would be a scandal of maladministration, not the political vendetta that has been alleged. Because, after all, the IRS does HAVE to determine whether groups qualify for 501 c 4 status, and then whether they are in compliance with c 4 standards of conduct—that is the agencies job, whether the groups are progressive or conservative.

Trevor Potter

From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Joe La Rue
Sent: Thursday, August 08, 2013 10:15 AM
To: Smith, Brad
Cc: law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: Re: [EL] BOLOs, TAGs, and Drums

Brad, Brad, Brad. Didn't you hear? The IRS only targeted progressive, liberal groups. Or perhaps it is that no group was targeted; the IRS was just doing its job. Regardless, there was no targeting of conservative groups. The extra scrutiny applied to them, as well as the delays they experienced, was all warranted. It doesn't matter what the IRS says. After all, if we're going to revise history, and ignore the IRS's admissions against interest (which is what some are doing), then we might as well do it on a large scale. Go big or go home, right? So let's beat the drum together that the IRS got it all wrong when it admitted it had improperly targeted conservative groups.

My only question, I guess, is why is that a drum that anyone would want to beat? Are some so politically driven that we cannot acknowledge that something dreadfully wrong happened here, simply because it happened to the other side? If the IRS can do it to conservative groups in the mid-2010s, then they can do it to progressive groups if the White House (or even just the IRS) becomes more conservative. And I continue to beat my drum and say: it doesn't matter whether it was all conservative groups, or all progressive ones, or a mixture of each that was targetted. What happened was wrong. And I remain shocked that that is not something that we can all agree on.

Joe


Joe
___________________
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On Wed, Aug 7, 2013 at 9:31 PM, Smith, Brad <BSmith at law.capital.edu<mailto:BSmith at law.capital.edu>> wrote:
Where does this idea come from that they were evenly distributed? That's not what the IRS says.


Bradley A. Smith

Josiah H. Blackmore II/Shirley M. Nault

   Professor of Law

Capital University Law School

303 E. Broad St.

Columbus, OH 43215

614.236.6317<tel:614.236.6317>

http://law.capital.edu/faculty/bios/bsmith.aspx

________________________________
From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] on behalf of Mark Schmitt [schmitt.mark at gmail.com<mailto:schmitt.mark at gmail.com>]
Sent: Wednesday, August 07, 2013 10:54 PM
To: law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: Re: [EL] BOLOs, TAGs, and Drums
This seems like a very new drum indeed. You seem to be saying that the very idea of a "BOLO" list, or what I've also heard called an "emerging issues" list, is illegitimate. I don't have the knowledge of IRS procedures that you do, but this is not an argument I've heard before.
It really doesn't seem complicated. Groups with the word "progressive" in their names or descriptions were getting some extra scrutiny based on long-established practice. That makes sense: The Progressive Policy Institute was established in 1991. Center for American Progress and the c(4) American Progress Action Fund in 2003. Progressive States Network,  Progress Now and a bunch of "Progress [state]" c(4)s in 2005-2007, continuing to recent years. Those are the ones that jump to my mind, but there are others.  The IRS had a lot of time to absorb and consider those groups, and still their applications took many months. "Tea Party," as we know, was not a term that organizations were using before 2009-2010. And rather than the slow growth curve of "progressive" c(4)'s, a lot of groups using Tea Party and related but also new terms were created quite rapidly. Hence, it was an "emerging issue," or something to look out for, on which a formal protocol had not yet been established, but might need to be.

What am I missing here? Both "progressive" and "Tea Party" groups were flagged for scrutiny, One term was old, the other was new. Both faced delays, questions and obstacles. Maybe those delays were themselves "wrong," as some have alleged, or maybe not, but they were evenly distributed. If one came from  one kind of list, and the other from another list, why do we care?

Mark Schmitt
Senior Fellow, The Roosevelt Institute<http://www.rooseveltinstitute.org/>
202/246-2350<tel:202%2F246-2350>
gchat or Skype: schmitt.mark
twitter: mschmitt9

On Wed, Aug 7, 2013 at 2:02 PM, <BZall at aol.com<mailto:BZall at aol.com>> wrote:
Sigh, not to continue Prof. McDonald's "drum" analogy further, but there seems to be a continuing error of conflation in these discussions, both on the Hill and in this thread. If Glenn Kessler ("The FactChecker" from Jeff Bezos's newspaper) can figure this one out, so can those looking for the difference between treatments:

"Meanwhile, Democrats have highlighted information that they say undercuts the thrust of the Inspector general’s report. While that report focuses on scrutiny of “tea party” and related groups — which had been placed on “be on the lookout” (BOLO) lists — Democrats released documents<http://democrats.waysandmeans.house.gov/sites/democrats.waysandmeans.house.gov/files/November%202010%20BOLO%20IRS0000001349-IRS0000001364.pdf> showing that the term “progressive” had been part of a “TAG [touch-and-go] Historical” list." http://www.washingtonpost.com/blogs/fact-checker/post/explainer-sorting-through-charges-and-countercharges-in-the-irs-probe/2013/07/02/1cc2f520-e352-11e2-aef3-339619eab080_blog.html

There is a difference between a BOLO list and a TAG list ("Touch and Go"). See, e.g., http://www.irs.gov/irm/part7/irm_07-020-006.html, explaining Touch and Go as a standard processing term in many highly-problematic areas. (Note: the Internal Revenue Manual is the internal description of standard procedures and can be relied on in certain tax or legal proceedings.) Real TAG analyses are generally reserved for abusive transactions (many of which involve exempt organizations) and have a very specific chain of command and authority, plus review. Potential terrorism issues, for example, are on TAG reviews. You can imagine the reviews those generate. "Compliance" project reviews are generally not worthy of the full TAG panoply. IRM 7.20.6.1.2.1.

To the extent we even know what they are/were, BOLOs, on the other hand, are a new and unreported (and apparently badly supervised) version of TAG lists that raised many of these issues. Like TAGs, BOLOs use key words in the database to identify possible transactions, but the differences are in the structure, supervision, and probably the choice of terms as being recognized for a particular definition of what the problem is. Who generated the terms? We don't know. Who reviewed the terms? We don't know. Who reviewed the selections based on those terms? We don't know. What was the process used once a selection was made? We don't know. Etc. What we do know is that everyone passed the buck or said they didn't know.

In other words, TAG reviews are what we expected the IRS to do if there had really been a problem; BOLOs are not. BOLOs are, for want of a better description, rogue TAGs, and no one wanted to grab that leash to bring them under control. THAT is the scandal; not that groups' applications were scrutinized, but that the process was overwhelmingly one-sided and unrestrained.

There is no IRM entry for BOLO lists, nor will there be, despite Cong. McDermott's entreaties. http://www.realclearpolitics.com/video/2013/06/27/rep_mcdermott_irs_should_keep_bolo_lists.html. Having seen them in action, I would be surprised if EO or any other part of IRS made the term "BOLO list" a routine part of the IRM in the future.

As I understood the more informed (or less utterly-clueless) of the discussions, the liberal groups were mostly on TAGs; the conservatives (and a few unlucky progressive exceptions) were on BOLOs. Note that in the attachments to the House Dems' complaint, pages 1-9 refer to TAGs; only after P. 10 is there a reference to BOLOs, but all the listings cited say they are for BOLOs. http://democrats.waysandmeans.house.gov/sites/democrats.waysandmeans.house.gov/files/August%202010%20IRS0000002503.pdf The same is true through the next few "BOLO" listings; it's really TAGs and BOLOs without discrimination.

Both inclusions were undoubtedly mistakes, but one was quickly resolved through a quick look at the TAG rules; the other was not and it grew and grew and grew.

Doesn't mean Prof. McDonald is wrong, and he'll undoubtedly explain why his drum still thrums alone, but it does add another beat to the mix.

Barnaby Zall
Of Counsel
Weinberg, Jacobs & Tolani, LLP
10411 Motor City Drive, Suite 500
Bethesda, MD 20817
301-231-6943<tel:301-231-6943> (direct dial)
bzall at aol.com<mailto:bzall at aol.com>
_____________________________________________________________
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In a message dated 8/7/2013 1:20:46 P.M. Eastern Daylight Time, mmcdon at gmu.edu<mailto:mmcdon at gmu.edu> writes:
The IRS issued BOLOs that used the keyword search approach to identify liberal groups, just as they did conservative groups. Unless, you mean to say that liberal and conservative groups were flagged as a general course of business, in which case I am inclined to agree with you. I say "inclined" since there is an outstanding question as to why more conservative groups were flagged than liberal (something I am sure someone will say to beat their drum). A likely non-nefarious explanation is that a greater number of conservative organizations filed for status, which is my belief until contradicting evidence comes to light.

The evidence that continues to come to light is entirely consistent with my initial postings on this matter. I'm in the fortunate position of only ever needing one drum to beat since I've never had a drum taken away.

============
Dr. Michael P. McDonald
Associate Professor
George Mason University
4400 University Drive - 3F4
Fairfax, VA 22030-4444

phone:   703-993-4191<tel:703-993-4191> (office)
e-mail:  mmcdon at gmu.edu<mailto:mmcdon at gmu.edu>
web:     http://elections.gmu.edu
twitter: @ElectProject


-----Original Message-----
From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Smith, Brad
Sent: Wednesday, August 07, 2013 12:45 PM
To: law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: Re: [EL] Lerner in her own words - "everyone" "screaming"

I'm surprised that Michael keeps thumping this drum since the Inspector General, and the IRS itself, have said quite clearly that conservative groups were targeted. The fact that some liberal groups were also snared, either in the criteria used to scrutinize conservative groups, or in the general course of business, really doesn't change that, and numerous analyses the numbers have verified the impact.

But having said that, it doesn't matter. Even if Michael were correct, that would change only the nature, and not the fact, of the scandal. And that, again, represents the problem.

Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
   Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
614.236.6317<tel:614.236.6317>
http://law.capital.edu/faculty/bios/bsmith.aspx

________________________________________
From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] on behalf of Michael P McDonald [mmcdon at gmu.edu<mailto:mmcdon at gmu.edu>]
Sent: Wednesday, August 07, 2013 11:43 AM
To: law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: Re: [EL] Lerner in her own words - "everyone" "screaming"

I remained silent with the "I told you so" when a litany of media reports finally came out showing how liberal organizations were flagged and treated the same as conservative organizations. But this is the story that will not die so here we go...

Where this logic fails is that the IRS included liberal groups in their treatment such as those advocating for the Affordable Care Act. When did the president or Democratic members of congress ever indicate that they wanted the IRS to go after groups advocating for Obama's signature legislative accomplishment? Or was that Republican members of Congress sounding those alarms? Perhaps when Lerner says "everyone" she means *everyone* and not just the president and his congressional allies. And if everyone was clamoring for action against their political opponents, how could any action taken by the IRS not be alleged as singling out a political opponent of someone?

============
Dr. Michael P. McDonald
Associate Professor
George Mason University
4400 University Drive - 3F4
Fairfax, VA 22030-4444

phone:   703-993-4191<tel:703-993-4191> (office)
e-mail:  mmcdon at gmu.edu<mailto:mmcdon at gmu.edu>
web:     http://elections.gmu.edu
twitter: @ElectProject

From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Smith, Brad
Sent: Wednesday, August 07, 2013 11:17 AM
To: Trevor Potter; Jason Torchinsky; law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: Re: [EL] Lerner in her own words - "everyone" "screaming"

And that is, to me, what the scandal has always been about. It's not that there was some White House order (although that wouldn't overly shock me). It's that the White House and the President publicly and repeatedly sounded the "alarm," and the need to get after these groups. It's that members of Congress repeatedly wrote to the IRS to demand that it take action or inquire  why it hadn't (and we know what such an inquiry means). It is that Democrats held show hearings all over Capitol Hill, wherever any committee could with any remote legitimacy claim some jurisdiction, to excoriate these groups. It is that Democrats publicly and private pressured the SEC and the FCC, as well as the IRS, to take action because the FEC would not and Congress was unable to pass DISCLOSE.

Of course the IRS responds to such posturing, inquiries, and vilification. That is the problem. And it continues, as Sen. Whitehouse held a hearing this spring openly accusing groups of violating the law, with no evidence; as Senator Levin promised to "investigate" these conservative organizations; as Senator Durbin sent out mass letters yesterday demanding to know if various persons and groups had in any way funded ALEC.

There was what reformers would call "an astroturf" campaign, headed up by prominent Democratic officeholders and aides, to drum an aura of crisis about the political participation of their political opponents, and then to demand that the huge federal bureaucracy step in to "do something" about it, in light of the fact that Congress could not muster the votes.

That is the problem, and it is exactly what we've been warning about for years would be one of the many problems with campaign finance regulation.

Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
   Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
614.236.6317<tel:614.236.6317>
http://law.capital.edu/faculty/bios/bsmith.aspx
________________________________________
From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] on behalf of Trevor Potter [tpotter at capdale.com<mailto:tpotter at capdale.com>]
Sent: Wednesday, August 07, 2013 11:04 AM
To: Jason Torchinsky; law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: Re: [EL] Lerner in her own words - "everyone" "screaming"
Jason

I know you are relying on a Breitbart piece, and it has an obvious point of view. However, even that piece does not say that there was any pressure from the "White House" on the IRS, and Breitbart is fair enough to note that there was a great deal of press coverage and editorials in 2010 about new 501 c4s which appeared to be doing  nothing but huge amounts election activity in 2010. As the article states:

"TIGTA's report contains a few key redactions which conceal precisely how the scrutiny of Tea Party groups began. Reading between the lines it seems media attention played a role. Plans by a Tea Party group to create a new 501(c)(4) were featured in stories at the NY Times and NPR just a couple weeks after Obama's statements about Citizens United. These stories apparently caught the attention of the IRS which regularly monitors news stories to be aware of developing issues."

Thus, the "everyone" wanting the IRS to "do something" in context appears to refer to the quite public and common outrage reported on in the press that essentially political entities were using 501 c 4 status to avoid disclosure of their donors which would be required under election law.

Trevor Potter

From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Jason Torchinsky
Sent: Wednesday, August 07, 2013 10:47 AM
To: law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: [EL] Lerner in her own words - "everyone" "screaming"

http://www.breitbart.com/InstaBlog/2013/08/06/Lois-Lerner-Discusses-Political-Pressure-on-the-IRS-in-2010

In case anyone missed this, here's Lois Lerner in her own words from 2010 explaining that "everyone" wanted the IRS to "do something."

This video according to the report was taken in the fall of 2010.

Implications of this?  I thought the IRS and the White House have maintained there was no pressure on the IRS.

-          Jason Torchinsky

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