Responsive Documents- CREW: IRS: Regarding Records Provided to Senate Finance Committee Chairman Max Baucus: 2/29/2012- 501c FOIA Response

8/2/2019 Responsive Documents- CREW: IRS: Regarding Records Provided to Senate Finance Committee Chairman Max Bau

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DEPARTMENT OF THE TREASURYINTERNAL REVENUE SERVICE

WASHINGTON, DC 20224

February 29, 2012

Adam RappaportCREW1400 Eye Street, N.W. Suite 450Washington, DC 20005Dear Mr. Rappaport:I am responding to your Freedom of Information Act (FOIA) request dated November 7,2011, that we received on November 14 , 2011.You asked for copies of any report, findings, or recommendations provided to Congressin response to the September 28, 2010, letter Senate Finance Committee ChairmanMax Baucus sent IRS Commissioner Shulman requesting the IRS survey major section501(c)(4), (c)(5), and (c)(6) organizations involved in political activity to determinewhether they are operated for the organizations intended tax exempt purpose, and areacting as conduits for major donors advancing their own private interests.I am enclosing a copy of the requested documents consisting of 26 pages. This is a fullgrant of your request.Your request for a fee waiver was considered and granted, however no fees wereincurred to process your request.If you have any questions please call Tax Law Specialist Valerie Barta, ID # 245581, at512-499-5211 or write to: Internal Revenue Service, HQ Disclosure, 2980 BrandywineRoad, Stop 211, Chamblee, GA 30341. Please refer to case number F12318-0088.

Sincerely,

Marie A. TwarogDisclosure ManagerHeadquarters (HQ) Disclosure Office

PRIVACY, GOVERNMENTALLIAISON AND DISCLOSURE

Enclosure


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The Honorable Douglas H. ShulmanCommissionerInternal Revenue ServiceI Ill Constitu tion Avenue, N.W.Washing ton , DC 20224Via Electronic Transmis!ion GONG. CORA. BRHADear Commissioner Shulman:

The Senate Finance Committee has jurisdiction over revenue matters, and theCommittee is responsib le for conducting oversight of the administration of the federal laxsystem, including matters involving lax-exempt organizations. The Committee hasfocused extensive ly over the past decade on whether taxexempt groups have been usedfor lobbying or othe r financial or political gain.The centra l question examined by the Committee has been whether certa incharitable or social welfare organiza tions qualify for the tax-exempt sta tus provided

under the internal Revenue Code.Recent media reports on various 501(c)(4) organization s engaged in politicalactivity have raised serious questions about whether such organizations are operating incompliance with the Internal Revenue Code.The law requires tha t political campaign activity by a 501 (c)(4), (cX5) or (cX6)entity must not be the primary purpose of the organization.If it is determined the primary purpose of the 501(cX4), (cX5) and (cX6)organizat ion is political campaign activity the tax exemption for that nonprofit can beterminated .Even if polit ical campaign activity is not the primary purpose of a 5O l(c )(4),(c)(5) . and (cX6) organization, it must notify its members of the portion of dues paid dueto political activi ty or pay a proxy tax under Section 6033(e).

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United states enatcCOMMITTEE ON FINANCE

WASHINGTON, DC 20510-6200

September 28, 20 18,

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Based on your report I plan to ask the Committee to open its own investigationand/or to take appropriate legislative action.Sincerely,

QL-Max BaucusChairman


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WASI-((NGTON. DC. 20224

February 17, 2011

The Honorable Max BaucusChairman Committee on FinanceUnited States SenateWashington, DC 20510Dear Mr. Cha irm an:I am responding to your letter about political cam pa ign activities of organizationsclaiming to be tax exempt under sections 501(c)(4), (5) and (6) of the Interna l RevenueCode (the Code ). You wrote that such activities may be inconsistent with the tax-exempt status of these organizations. You asked us to survey major 501 (c)(4), (5) and(6) organizations involved in political cam paign activity to examine whether they areoperated for the organizations intended tax exempt purpose and to ensure that politicalcampaign activity is not the organizations primary activity.To meet the requirements for tax exempt ion, a section 501(c)(4) , (5) or (6) organizationmust engage primarily in activities that further its exempt purpose. As youacknowledge in your letter, under the law, sect ion 501(c)(4), (5) and (6) organizationsmay engage in political campaign intervention, so long as the intervention, along withany other non-exempt activity , Is not their primary activity. They also may conductunlimited issue advocacy and lobbying , as long as those activ ities are germane to theirexempt purposes. To determine the primary activities of an organ ization , includingde term ining whether political campa ign activity is a prim ary activity of an organization,we must wait until the organization files its annual information return to review theorganizations activities for the entire year, as well as the facts and circumstancessu rrounding those activities. Only after a review of all the relevant information, includingall expenditures and volunteer time, can we determine whether the organization ismeeting the requirements for exemption , and whether any tax is due. This makes itdifficult for us to assess during the tax year whether an organization claiming to beexempt under 501(c)(4) , (5) or (6) is complying with the applicab le limits on politicalcampaign activity. Also, many organizat ions permissibly extend their due date for filingtheir annual information re turns, which increases the delay between any im properactivity that an organization conducted and our receipt of the information needed toassess the organizations com pliance with the legal requirements.We face an additional challenge in the initial formation of these organizations. The factthat these types of organ izat ions have no legal requiremen t to file an application with usto seek a determinat ion that they are exempt within section 501(a) results in many suchorganizations essentially self declaringw exemption without our determination as to

COMMISSiONER


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2exempt status. This means we do not have an opportunity to review the statedpurposes and actMtles of such an organization before it flies one or more Forms 990.We share your concern that tax-exempt organizations of all types comply with theapplicable laws governing political campaign activities and no t use them for improperpurposes. We took a major step in 2008 to enhance the reporting of tax-exemptorganizations other than charities (including those described in sectIon 501 (c)(4), (5), or(6)), by requiring them to provide specific information on the annual Form 990 abouttheir political campaign activities. Requiring this information makes the organizationspolitical campaign actMties more transparent to us and to the general public. We usethis information in determining if political campaign activity is an organizations primarypurpose and whether any tax may be due.in the work plan of the Exempt Organizations Division, we announced that beginning inFY2O1 1, we are increasing our focus on section 501 (c)(4), (5) and (6) organizations.With the additional information available on the new Form 990, we will look at issuesrelating to political activity, inurement, and the extent of compliance with therequirements for tax exemption by organizations that self-Identify themselves underthese sections. We appreciate your request to conduct a survey of these types oforganizations, bu t given the liming of information challenges discussed above, we feelthat this is not likely to provide us with the necessary compliance Information, in ou rview, focusing our efforts on the annual information returns that we receive from theseorganizations is most appropriate.To ensure that tax-exempt organizations follow the tax laws, we are committed to abalanced program overseeing a wide range of tax-exempt organizations, includingthose exempt under the sub-sections cited in your letter. Additional information on therelevant law Is In the enclosure.Thank you for your attention to this area of the law. We appreciate your continuingsupport of our efforts to administer the tax laws that apply to tax-exempt organizations,and we welcome the opportunity to meet with you and your staff to chscuss thesematters.Please call me at (202) 622-9511, or Floyd Williams, Director of Legislative Affairs, at(202) 622-4725, if you need additional information or would like to schedule a meeting.

Sincerely,

L)QLJ H. ShulmanEnclosure


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legislature, any local council, or sim ilar governing body, or by the public in areferendum, initiative, constitutiona l amendment, or similar procedure.Political campaign activ ity is the attempt to in fluence the election of candidates to publicoffice. This includes any ac tivities that favor or oppose one or more candidates forpubl ic office, such as candidate endorsements, contribut ions to politica l campaignfunds, or public statements of pos ition (verbal or writ ten) made by or on behalf of anorganization in favor of, or in opposition to, any candidate for public office.General advocacy includes activity attempting to influence the public on issues ofconcern to the organization, attempting to influence actions by the executive branch ofgovernment such as issuance of regulations, and activ ities intended to encouragepeople to participate in the electoral process in a manner that does not favor or opposeany particular candidates.The IRS bases its determination of whether an activity constitutes lobbying or politicalcampaign activity on all of the relevant facts and circumstances. Consequently, acommunication made shortly before an election that identifies a candidate and takes aposition may not constitute political campaign activity in certain circumstances. SeeRev. Rul. 2004-6 for examples of the facts and circumstances considered in makingsuch a determination.Advocacy by Tax-Exempt OrganizationsAs the chart be low illustrates, the differen t types of tax-exempt organizations discussedabove have differen t rules as to the types of advocacy they may conduct consistent withtheir tax-exempt status. Engaging in each type of advocacy through some form oftax-exempt organization is possible, but not all types of tax-exempt organizations canengage in each type of advocacy.

501(c)(3) 501(c)(4) 501(c)(5) 501(c)(6) 527Receive Tax-Deductib leCharitable Contr ibutions YES NO NO NO NOEngage in Legislative

Advocacy LTD YES YES YES LTDEngage in Cand idate ElectionAdvocacy NO LTD LTD LTD YESEngage in Public AdvocacyNot Related to Legislation or YES YES YES YES LTD

Election of Candidates

By statute, section 501(c)(3) charitable organizations may not engage in lobby ingactivity as a substantial activ ity and are absolutely prohibited from engaging in politicalcampaign activ ity . They may engage in other advocacy activities, includingencouraging people to participate in the electoral process in a manner that does not


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periodically report information on their contributions and expenditures using Form 8872unless they meet the requirements of a qualified state or local political organization.These forms are also publicly available on the IRS web site. As only those section 527political organizations that filed Form 8871 must file Form 8872, a section 527 politicalorganization that is not exempt because it has not filed Form 8871 is not required to fileForm 8872. Thus, an organization that did not qualify as a section 501 (c)(4)organization because its primary activ ity was political campaign activity and thereforewas an organization described in section 527 would have no requirement to disclosecontributor information unless and until it filed Form 8871.Section 527 political organizations report the ir taxable income on Form 1 120-POL.Under section 6103, this form is not publicly disclosable. While the taxable income oftax-exempt section 527 political organizations consists primarily of investment income,the taxable income of those section 527 organizations that are not exempt because theyhave not filed Form 8871 includes all income, includ ing con tributions. However, thoseorganizations have no requirement to disclose any information other than the aggregateamount of those contribut ions on Form I 120-POL.Section 501 (c)(4) , (5), and (6) organizations use Form 11 20-POL to report any tax dueunder section 527(f). If those organizations pay the proxy tax under section 6033(e),they report it on Form 990-T. While the Forms 990-T that section 501 (c)(3) charitableorganizations file are required to be public ly disclosed, those that section 501(c)(4), (5),and (6) organizations file are not.


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Page 1 of3CCU Case Detail Results: 2010-15106

Type Due Date Received Date Document Date Closure DateLA Tracking 11/09/2010 09/29/2010 09/28/2010 02/17/2011NarrativeTR Field TAMIS Field Related FieldOther Field Legacy System FieldFormatLetterIssueEP/EO IssuesTopicLA TRACKING CASE-PLEASE PREPARE RESPONSE FOR THE COMMISSIONERSSIGNATURE-Chairman of the Senate Finance Committee (SFC) wrote to theCommissioner about his concerns with lobbying practices or other financial orpolitical gain by tax exempt organizations. He is requesting the IRS surveymajor 501(c)(4), (c)(5) and (c)(6) organizations involved in political activity toexamine whether they are operated for their intended tax exempt purpose.Special InstructionsThe attached congressional inquiry requires special handling. The analystworking this case *must* contact Mary Dash at (202) 622-6833 or MarcieWilliams (202) 622-5197. Please print and follow the attached instructions forresponding to LA Tracking controls.Case Creation Information By: Alexander, Bonnie On: 09/29/2010

Assignment_HistoryAdded On Added By Office Special Instructions11/05/2010 Cumbuka Commissioners Office11:09 Ortez09/29/2010 Bonnie Tax Exempt/Government10:10 Alexander Entities09/29/2010 Cynthnia EO-Rulings and03:38 Brown Agreements02/17/2011 Dorothy C&L-Office of Legislative03:45 Becones Affairs02/02/2011 Gloria Commissioners Office

http://ds0006 1 .dcc. irs.gov:7777Ietrak-cclpage.request.do?pagepage.ccu.... 12/20/201 1


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09:19 Henning01/11/2011 Cumbuka Deputy Commissioner, Signature package04:34 Ortez Services & Enforcement prepared for DeputyCommissionerssignature.01/06/20 11 Cumbuka Communications & Please assign to12:53 Ortez Liaison Legislative Affairs.

Case Event Log HistoryDate Type Action Comment Added By02/17/2011 Closure Closed - Final response signed by CumbukaResponse Commissioner. OrtezAttached02/17/2011 Action Signed Package signed by DorothyCommissioner. Becones

Notified/assigned package tocreating office (Leg. Affairs) ofcase pick up and processingaccordingly.02/17/2011 Action Comments Commissioner is still reviewing Marciepackage. Williams02/01/2011 Action Review Received case from DCSE office. DorothyUnder Chief of Staff review. Becones02/02/2011 Action Approval Reviewed and approved by the Gloria

Office of the DCSE. Hancicarried Henningto Commissioners office.01/06/2011 Action Reopened Reopening case to attach Cumbukacorrect final response to OrtezChairman Baucus.01/05/2010 Action Comments Legislative Affairs received draft Cumbukaresponse from Nikole Flax. Ortez11/05/2010 Closure Closed - Final responses attached. CumbukaResponse Ortez

Attached11/05/2010 Action Change of Deputy Commissioner Steve CumbukaSig nature Miller will sign final response. OrtezAuthority01/06/2011 Action Comments Legislative Affairs prepared Cumbukasignature package on 1/6/11. Ortez

Page 2 of 3

10/29/2010 Acton Comments clarification for note 10/21,Deputy Commissioner forMa rshalleI a c kso n

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Page 3 of 3Enforcement and Service (SteveMiller)

WorkPhone(202)224-2651

Fax Address511HartSenateBuilding

Email HomePhone

10/2 1/2010 Action Extension per staff attorney-The letter is Marsha lieRequest pending before the Deputy acksonCommissioner for review10/21/2010 Action Due Date The Due Date was revised From: MarshalleRevised 10/21/2010 To: 11/09/2010 Jackson

Case FromSalutation (Name (Email (Phone (Fax Iceil Phone (Address (City/State/Z

Case Addressee

Contact Type

Salutation (Name (Email (Phone JFax (Cell Phone (Address (City/State/ZipI

SalutationCase Contact

CongressionalNameMaxBaucus

City/State/ZipWashingtonDC 20510

Case DocumentsDate Source File Name Description02/01/2011 Final Baucus_15106.doc Final response preparedResponse by Leg Affairs forsignature package09/28/2010 Incoming Baucus_15106.pdf Incoming Letter02/01/2011 Final Action Routing Action Routing SheetResponse Sheet 15106.pdf02/17/2011 Final Final_Baucus_15106.pdf Final response signed byResponse Commissioner.01/25/2011 Final LTR-2010-15106-Baucus- Final response revised byResponse RevOl2l2OlLdoc the Office of the DCSE01/25/2011 Final Enclosure_15106.doc EnclosuresResponse

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WASHINGTON, DC. 20224

February 17.2011

The Honorable Orrin G. HatchUnited States SenateWashington, DC 20510Dear Senator Hatch:I am responding to your letter on the tax compliance of organizations claimingexemption under sections 501 (c)(4), (c)(5), and (c)(6) of the internal Revenue Code.To meet the requirements for tax exemption, a section 501 (c)(4), (5) or (6) organizationmust engage primarily in activities that further its exempt purpose. Under the law,section 501 (cX4), (5) and (6) organizations may engage in political campaignIntervention, so long as the intervention, along with any other non-exempt activity, is nottheir primary activity. They also may conduct unlimited issue advocacy and lobbying, aslong as those activities are germane to their exempt purposes. As you acknowledge inyour letter, to determine the primary activities of an organization, induding determiningwhether political campaign activity is a primary activity of an organization, we must waituntil the organization files its annual information return to review the organizationsactivities for the entire year, as well as the facts and circumstances surrounding thoseactivities. Only after a review of all the relevant information, including all expendituresand volunteer time, can we determine whether the organization is meeting therequirements for exemption, and whether any tax is due. This makes it difficult for us toassess during the tax year whether an organization claiming to be exempt under501 (c)(4), (5) or (6) is complying with the applicable limitations on political campaignactivity. Also, many organizations permissibly extend their due date for filing theirannual information returns, which increases the delay between any improper activitythat an organization conducted and our receipt of the information needed to assess theorganizations compliance with the legal requirements.We face an additional challenge in the initial formation of these organizations. The factthat these types of organizations have no legal requirement to file an application with usto seek a determination that they are exempt within section 501(a) results in many suchorganizations essentially self declaring exemption without our determination as toexempt status. This means we do not have an opportunity to review the statedpurposes and activities of such an organization before it files one or more Forms 990.We took a major step in 2008 to enhance the reporting of tax-exempt organizationsother than charities (including those described in section 50I(c)(4), (5), or (6)), byrequiring them to provide specific information on the annual Form 990 about their

COMWI$IONER


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2political campaign activities. Requiring this information makes the organizationspolitical campaign activities more transparent to us and to the general public. Thisinformation is used by the IRS in determining if political campaign activity is anorganizations primary purpose and whether any tax may be due.In the work plan of the Exempt Organizations Division. we announced that beginning inFY2OI 1, we are increasing our focus on section 501(c)(4), (5) and (6) organizations.With the additional information available on the new Form 990, we will look at issuesrelating to political activity, inurement and the extent of compliance with therequirements for tax exemption by organizations that self-identify themselves underthese sections. Our efforts principally will be focused on the annual information returnsthat we receive from these organizations.To ensure that tax-exempt organizations follow the tax laws, we are committed to abalanced program overseeing a wide range of tax-exempt organizations.Thank you for your attention to this area of the law. I am sending a similar letter toSenator Kyl. We appreciate your continuing support of our efforts to administer the taxlaw that applies to tax-exempt organizations, and we would welcome the opportunity tomeet with you and your staff to discuss these matters.If you have any questions or would like to schedule a meeting, please call me at(202) 622-9511, or Floyd Williams, Director of Legislative Affairs, at (202) 6224725.


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DEPARTMENT OF TH E TREASURYINTERNAL REVENUE SERVICE

WASHINGTON, D.C. 20224

Feb ruary 17,2011

The Honorable Jon KylUnited States SenateWash ing ton , DC 20510Dear Senator Kyl:I am responding to your letter on the tax compliance of organizations claimingexemption under sections 501(c)(4), (cX5), and (c)(6) of the Internal Revenue Code.To meet the requirements for tax exemption, a section 501 (c)(4), (5) or (6) organizationmust engage primarily in activities that further its exempt pu rpo se. Under the law,section 501 (c)(4), (5) and (6) organizations may engage in political campaigninterven tion, so long as the intervention, along with any other non -exempt activity, is nottheir primary activity. They also may conduct unlimited issue advocacy and lobbying , aslong as those activities are germane to their exempt purposes. As you acknow ledge inyour letter, to determ ine the primary activities of an organizat ion, including de term iningwhether political campaign activity is a prim ary activity of an organization , we must waituntil the organ iza tion files its annual information return to rev iew the organizationsactivities for the entire year, as well as the facts and circumstances sur rounding thoseactivities. Only after a review of all the relevant info rmation, including all expendituresand volunteer time, can we determine whether the organizat ion is meeting therequirements for exemption, and whethe r any tax is clue. This makes it difficult for us toassess dur ing the tax year whether an organ ization claim ing to be exempt under501(c)(4), (5) or (6) is complying with the applicable limitations on political campaignactivity. Also, many organ izations permissibly extend their due date for filing theirannual information returns , which increases the delay between any improper activitythat an organiza tion conduc ted and our receipt of the information needed to assess theorganizations compliance with the legal requirements.We face an additional challenge in the initial formation of these organ iza tions. The factthat these types of organizations have no legal requirement to file an appl ication with usto seek a determination that they are exempt within sect ion 501(a) results in many suchorganizations essentially self declaring exemption without our de termination as toexempt status. This means we do not have an opportunity to review the statedpurposes and ac tivities of such an organization before it files on e or more Forms 990.We took a major step in 2008 to enhance the reporting of tax -exempt organizationsother than charities (including those described in section 501(c)(4), (5), or (6)), byrequ iring them to provide specific information on the annual Form 990 about their

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2political campaign activities. Requiring this information makes the organizationspolitical campaign activities more transparent to us and to the general public. Thisinformation is used by the IRS in determining if political campaign activity is anorganizations primary purpose and whether any tax may be due.In the work plan of the Exempt Organizations Division, we announced that beginning inFY2O1 1, we are increasing our focus on section 501 (c)(4), (5) and (6) organizations.With the additional information available on the new Form 990, we will look at issuesrelating to political activity, inurement and the extent of compliance with therequirements for tax exemption by organizations that self-identify themselves underthese sections. Our efforts principally will be focused on the annual information returnsthat we receive from these organizations.To ensure that tax-exempt organizations follow the tax laws, we are committed to abalanced program overseeing a wide range of tax-exempt organizations.Thank you for your attention to this area of the law. I am sending a similar letter toSenator Hatch. We appreciate your continuing support of our efforts to administer thetax law that applies to tax-exempt organizations, and we would welcome the opportunityto meet with you and your staff to discuss these matters.If you have any questions or would like to schedule a meeting, please call me at(202) 622-9511, or Floyd Williams, Director of Legislative Affairs, at (202) 622-4725.

Sincerely,

Doug as H. Shulman


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Action Routing SheetRequest for Signature of: Commissioner Douglas H. SliulmanSubject: Political campaign activities of tax exempt organizationsi-trak Control #: 2011-15432 Due Date: February 4,2011

Secretary Reviewer Commenteviewing Office InitlaliDate Initial/DateFlOyd 1. WIlliams, Director Legislative AffairsSteven T. Miller, Deputy Commissioner forServices & Enforcement

Carol Campbell, Deputy Chief of StaffJonathan Davis, Chief of Staff

Douglas H. Shulman, Commissioner

Date: February 1, 2011

summary:Senator Kyl arid Senator Hatch wrote about political campaign actMties of tax exempt organizations.

PreparedBy: Phone: Office Symbols: Bldg/Room #Christinne Rodriguez 202-927-4372 CL:LA Main IR- Room 3240


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Page 1 of5CCU Case Detail Results: 2011-15432

Type Due Date Received Document ClosureDate Date DateCongressional 02/04/2011 10/07/2010 10/06/2010 02/17/2011CorrespondenceNarrativeTR Field TAMIS Field Related FieldOther Field Legacy System FieldFormatFaxIssueExempt OrganizationTopicSen. Hatch and Sen. Kyl wrote about the Senate Finance Committees requestto survey major 501(c)(4), (c)(5) and (c)(6) organizations.Special InstructionsLEGISLATIVE AFFAIRS IS THE CONTROLLING OFFICE FOR THIS INQUIRY.PLEASE CALL 202-622-3730 IF YOU HAVE QUESTIONS. PLEASE CLEAR DRAFTRESPONSE THROUGH LEGISLATIVE AFFAIRS. FAX THE RESPONSE ANDINCOMING LETTERS TO MARY DASH AT 202-927-9613. DO NOT EMAIL DRAFTUNLESS SPECIFICALLY REQUESTED AS PART OF LA TRACKING PROCESS.Case Creation Information I By: Graves, Diane On: 10/07/2010

Assignment_HistoryAdded On Added By Office Special Instructions10/13/2010 Winonna EO-Rulings and Agreements11:08 1-lolton10/07/2010 Diane Tax Exempt/Government08:49 Graves Entities02/17/2011 Dorothy C&L-Office of Legislative03:46 Becones Affairs02/0212011 Gloria Commissioners Office09:20 Henning01/21/2011 Winonna Deputy Commissioner, Forwarding control

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Page 2 of 508:55 Holton Services & Enforcement per Glorias request.WH

Case Event Log HistoryDate Type Action Comment Added By02/17/2011 Action Comments Floyd Williams will Cumbukahand-deliver final Ortezresponse to the offices

of Senators Kyl &Hatch on February 18,2011.

02/17/2011 Closure Closed - Response Final responses signed CumbukaAttached by the Commissioner Ortezattached.02/17/2011 Action Signed Signature package Dorothysigned by BeconesCommissioner.Notified/assigned tocreating office (Leg.Affairs) for case pickup and processingaccordingly.02/01/2011 Action Review Received case from DorothyDCSE office. Under Becones

Chief of Staff review.02/02/2011 Action Approval Reviewed and Gloriaapproved by the Office Henningof the DCSE.Handcarried toCommissionersoffice.

01/14/2011 Action Extension Request per staff attorney- MarshallePlease update the due acksondates of these E-Traksuntil Friday, February4, 2011. I will letLegislative Affairsknow. Thanks, Mattew

01/14/2011 Action Due Date Revised The Due Date was Marshaflerevised From: Jackson01/14/2011 To:hnp ://ds0006 1 .dcc.irs.gov :7777Ietrak-cclpage.request .do?page=page.ccu.... 12/20/201 1


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Marshallelackson

02/04/2011Page 3 of 5

01/11/2011 Action Corrections/Changes Draft response Christinnereceived in Legislative RodriguezAffairs for review on01/11/2011.Legislative Affairsreturned changes toFloyd Williams on01/11/11.

01106/2011 Action Comments Legislative Affairs Cumbukapreparing signature Ortezpackage for SteveMillers signature.

12/10/2010 Action Extension Request per staff attorney- Marshalleresponse letter is lacksonpending withCommissionerShulmans Office.

12/10/2010 Action Due Date Revised The Due Date was Marshallerevised From: ackson12/10/20 10 To:01/14/201111/10/2010 Action Extension Request per staff attorney- Marshalleupdate E-Trak with the ackson

new due date ofDecember 10, 2010for both items. Theresponses are pendingwith the DeputyCommissioner (StevenT. Miller) for review. Ifyou have anyquestions, let meknow.

11/10/2010 Action Due Date Revised The Due Date was Marshallerevised From: ackson11/09/20 10 To:12/10/2010

10/29/2010 Action Extension Request per staff attorney, due Marshalledate changed to 11/9 ackson10/29/2010 Action Due Date Revised The Due Date wasrevised From:

http ://ds0006 1. dcc.irs.gov :7777/etrak-cc/page.request. do?page=page.ccu . .. . 12/20/201 1


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Salutation IName lEmail IPhone IFax ICell Phone IAddress cityi5tateIZip

Fax AddressUnitedStatesSenate730HartSenateOfficeBuildingUnitedStatesSenate104HartSenateOfficeBuilding

City/State/ZipWashingtonDC 20510

WashingtonDC 20510

Case DocumentsDate Source File Name Description02/01/2011 Final LTR-2011-15432-Kyl- Kyl final draft responseResponse Rev02012011.doc02/01/2011 Final LTR-2011-15432-Hatch- Hatch final draftResponse Rev02012011.doc response10/06/2010 Incoming Sen. Hatch & Sen. Kyl Incoming e-mail15432.pdf02/01/2011 Other Action Routing LegAffARSSheet_15432 .pdf

Case From

Case Addressee

Contact Type

Salutation IName (Email (Phone IFax ICell Phone IAddress (City/State/Zip

SalutationCase Contact

NameCongressional

EmailSen.

HomePhone WorkPhoneJonKyl (202)224-4521

Congressional Sen. OrrinHatch (202)224-5251

http:J/ds0006 1. dcc. irs.gov :7777/etrak-cc/page.request.do?pagepage.ecu.... 12/20/2011


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Page 5 of 502/17/2011 Final Hatch_Final_15432.pdf Final response to HatchResponse signed byCommissioner.02/17/2011 Final Kyl_final_15432.pdf Final response to KylResponse signed byCommissioner

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