Did Tea Party “godfathers” break federal election law in Illinois?

Would it surprise you to know that the Sam Adams Alliance staffer Eric Odom “created” the first “tea party” organization (now, American Liberty Alliance) after that famous CNBC rant by Rick Santelli about how “he shouldn’t have to pay YOUR mortgage”?  Or this:

The American Liberty Tour is a collaborative project of the American Liberty AllianceAmericans for Limited Government and the Sam Adams Alliance.

Yeah. Those guys

But the question is this: is anybody going to enforce campaign laws, or doesn’t anybody have to obey laws anymore?

Did Howie Rich Break the Law in Illinois … Again?

by Hart Williams © 2010

CPAC sponsors Americans for Limited Government of Fairfax, Virginia may well have finally crossed the line into blatant lawbreaking. Blatant, that is, unless lawyers can well, LAWYER it. It seems a plain violation of  US Tax Code, engaging in a brazen and successful attempt to “take out” a Republican not deemed “Republican” enough in the Illinois primary for IL Congressional District 10.

Sure, for years they’ve sneered at regulations and regulators, but not only did they seemingly blatantly break federal tax law regarding “Civic Associations” (like a volunteer fire department, which is what a 501(c)4 is classified as in tax law), but they’ve actually DOCUMENTED the activities in a seemingly perfect chain of evidence!

We took out Beth Coulson! Copyright Americans for Limited Government!

Is this the culmination of a long train of abuses by the “term limits” crowd that refuses to term limit itself out of acting as a private legislature?

One might have thought it happened when they funnelled millions of anonymous dollars into California, Missouri,  Nebraska and other states in 2006, from the mysterious “America At Its Best,” whose agent and director was Bill Wilson, President of Americans for Limited Government (and was at the time Emphasis added).

William Wilson signed the 2006 ALG 501(c)3 tax return

QUOTE: … And William “Bill” Wilson we know from “Americans for Limited Government,” “Club For Growth, State Action,” “Parents In Charge,” and from “America At Its Best” whose registered agent he is — and from the 990s of several of Rich’s organizations, where, for instance, “William Wilson” received $26,000 as the only paid Board member of U.S. Term Limits in 2003. [Wilson is often the only compensated board member in several of the Howie Rich groups, so you have to multiply that $26,000 several times to compute what his actual salary is in any given year.] … When you look up the Legislative Education Action Drive, you get the IRS 990 for “Parents In Charge” which was founded, as we’ve reported by Howard Rich, Eric O’Keefe and Bill Wilson. … Founded in March 2001 by Howard Rich, Eric O’Keefe and Bill Wilson …You will also recall that the Walton Family Foundation handed the brand new “Parents In Charge Foundation” $10 million in 2001.

He was on the secret board of the mysterious America At Its Best that slushed millions of dollars all over the West in 2006 …

On the AAIB 2006 tax return, filed on October 19, 2007 nearly a year AFTER the election in which AAIB would disclose nothing about its funding. AAIB spent $4,834,168  on “RESEARCH AND EDUCATION REGARDING LIMITED GOVERNMENT IDEAS,” $722 on SUPPLIES and $979 on “OFFICE EXPENSE.” And then AAIB vanished, so little cash activity that it has never filed another tax return.

(Oh, and it’s the SAME William Wilson. I checked.)

More about all that in a minute. Here’s the information that caught my eye [emphasis added]:

Chicago Daily Observer
Pullen aims at Coulson in the 10th
31 JANUARY 2010

[* This article was syndicated via RSS from Illinois Review. The views represented do not necessarily represent those of the Chicago Daily Observer.]

by Penny Pullen

This is an invitation for all good men and women to come to the aid of their country. In the 10th Congressional District, candidate Beth Coulson, a liberal GOP state representative from Glenview, has been snowing the mailboxes of voters in the district with literature portraying herself as a commonsense, fiscal conservative. The record shows quite the opposite. Rep. Coulson is a friend of trial lawyers and unions, has voted to hike taxes, sponsored an Illinois Cap & Trade bill, takes radical positions on social issues and has taken contributions from ACORN. SEIU has now arrived in the 10th district to aid her in seizing the Republican nomination to Congress. But teams of patriotic Americans are going out in the district in 2s and 3s to provide documented information to Republican voters outlining the truth about Beth Coulson’s voting record. You are invited to join the team. Volunteers are welcome, and those who would like to be compensated can earn $50/day for working a 4-hour shift, going to targeted voters’ doors simply to offer them information to help inform their vote – not actually advocating for or against a candidate and not engaging in conversation or answering questions. Starting at 9 a.m. Saturday (2 shifts 1/30), then one shift on Sunday afternoon and two on Monday. Call 224/223-4004 to inquire or simply go to the Wingate Hotel on the west side of Milwaukee Avenue just north of the River Road fork (south of Palatine Road). Instructions and materials will be provided. A project of Americans for Limited Government, a non-profit organization.

[* Which is not actually “by” Penny Pullen. She openly publishes a press release and puts her own name on it. Brava!] Get that?

… not actually advocating for or against a candidate and not engaging in conversation or answering questions.

Here’s Penny Pullen on the ALG-owned website that conducted the canvassing:

Penny Pullen and unidentified “friend”

But, you see, Beth Coulson is the state Republican representative in the Illinois legislature representing Glenview, Illinois. Jeepers. Glenview, Illinois.

Now, why does that ring a bell? Oh, I remember! That’s the return address of a political mailer I received in July 2006, that started this long journalistic questWhy was I getting mail from Chicago for an Oregon ballot initiative?

GLENVIEW, IL 60025-5159

And here is what I had found out about that address by October 24, 2006, after a summer and fall of researching and tracking Howie Rich’s money and minions through a thousand different masks, but always the same players:

Oh, and while we’re on the subject of new/old news, here’s a little breaking news on the old/new Colorado Howard Rich initiative on term limiting judges, funded almost entirely by “Colorado At Its Best” which also ponied up $50,000 to the California Prop. 90 Campaign:


GLENVIEW, IL 60025-5159

GLENVIEW, IL 60025-5159

GLENVIEW, IL 60025-5159

GLENVIEW, IL 60025-5159

240 WAUKEGAN RD # 200
GLENVIEW, IL 60025-5159

GLENVIEW, IL 60025-5159

GLENVIEW, IL 60025-5159

GLENVIEW, IL 60025-5159

The Tax Exempt World link doesn’t work anymore*, because Howie angrily “left” Illinois in a huff after the Center for Public Integrity unearthed documentation that the organizations hadn’t bothered complying with Illinois election law.

[* But, you can find ALG headquartered at the Glenview address in 2005,courtesy of the Colorado Secretary of State, appropriately enough for “RENTAL – TROJAN HORSE.”]

From the National Taxpayers Union blog (often teams with ALG)

(for an extra treat, click here and scroll to the bottom of the page)

Jeepers. Americans for Limited Government, the 501 (c) 4 organization that occupies the “civic league” non-profit niche, decided to actively GO AFTER a single candidate, calling it “voter education,” which is ALL that the law allows. But it can’t be against any individual candidate or ballot measure. Which is why the absurd disclaimer is added:

… not actually advocating for or against a candidate and not engaging in conversation or answering questions.

And this even more absurdist pronouncement:

Americans for Limited Government is a 501c4 and DOES NOT advocate the election or defeat of any candidate for public office.*

Saying something  doesn’t make it so. Even when you put it in italics and boldface type. (Emphasis THEIRS.)

Especially when it’s so absurdly blatant. Paying canvassers to distribute classical GOP smears against a candidate the weekend before the primary? Are you KIDDING us?

And this on their Code Red website:

I want to say thank you to Americans for Limited Government and to Conservative Code Red for coming to the 10th District to help educate the voters about the true voting record of one of our candidates for Congress here,” said former Illinois state legislator Penny Pullen.

ALG’s project, led by national political director Dan Tripp, put dozens of volunteers on the ground in IL-10 and “reached thousands of district residents,” according to Tripp.

The fliers stated that Coulson had taken tens of thousands of political dollars from unions and ACORN, voted to hike the state sales tax, repeatedly voted for pork-laden bills totaling hundreds of millions of dollars of taxpayer money, and sponsored and voted for legislation creating a carbon emissions cap to reduce Illinois emissions to 1990 levels.

Pullen’s message to ALG: “Thank you for coming and helping us get the word out on such a positive, well-documented, credible way.” [sic]

[* Naw. The strident nature of the disclaimer seems to indicate that they know they’re breaking the law.]

Some lawyer has given them instructions on just how close to the line they can walk and still maintain their “charitable” status. Here is what the IRS says about501 (c) 4 “Civic Leagues and Social Welfare Organizations“:

If your organization is not organized for profit and will be operated only to promote social welfare, you should file Form 1024 to apply for recognition of exemption from federal income under tax under section 501(c)(4). (page 46, IRS Pub. 557).

The law was expressly written to say: You’re getting a tax break as a “charitable” organization, even though you’re pushing a clear political agenda. But you CAN’T explicitly politick for or against any candidate or ballot initiative/voter referendum.

But that was before lawyers got ahold of it. (Y0u know lawyers.)

This is how the IRS describes a 501 (c) 4 (from pub 557, page 46):

Examples. Types of organizations that are considered to be social welfare organizations are civic associations and volunteer fire companies.

Let me read from IRS Publication 557 (“Tax Exempt Status for Your Organization” Rev. June 2008, Cat. No.  46573c):

Political activity. Promoting social welfare does not include direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office. (page 46)

And that is pretty plain language.

Here, from their flickr account on the Code Red website is step by step documentation that Americans for Limited Government (who advertised, remember for canvassers to earn $50 for a four hour shift) actively engaged in intervention in opposition to Beth Coulson’s bid for the GOP nomination for Illinois Congressional House District 10 ON THE WEEKEND BEFORE THE PRIMARY ELECTION!

First,  a flyer that you can see in the picture below:

Now, a screencap and a link to the .pdf flyer itself:

download the .pdf from the ALG/”CodeRed” website

That meeting above was to prepare for (paid?) canvassing. And here it is. Notice the kid in the car holding that Coulson flyer? (It’s the “Union” flyer HERE. And there’s the “Coulson Raised Your Taxes” flyer HERE.)

Nice of them to timestamp the photos for evidentiary purposes

And, here they are distributing them:

And here they are even better.

And here …

And here’s a nice closeup of the porch:

And here’s those same two kids with the Code Red/ALG organizer:

And here’s the license plate on the truck if anybody’s interested.

And here’s the truck:

That is what I would call straight up campaigning against a specific candidate. And the time stamp is probably very helpful in any criminal investigation.

Here’s what the IRS has to say about it.

The promotion of social welfare does not include direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office.

And here is the precise legal parsing and citation; you be the judge (exemptmeans YOU CAN’T DO THIS):

§ 527(e)(2). When an advocacy communication explicitly advocates the election or defeat of an individual to public office, the expenditure clearly is for an exempt function under § 527(e)(2).

However, when an advocacy communication relating to a public policy issue does not explicitly advocate the election or defeat of a candidate, all the facts and circumstances need to be considered to determine whether the expenditure is for an exempt function under § 527(e)(2).

In facts and circumstances such as those described in the six situations, factors that tend to show that an advocacy communication on a public policy issue is for an exempt function under § 527(e)(2) include, but are not limited to, the following:

a) The communication identifies a candidate for public office;


b) The timing of the communication coincides with an electoral campaign;


c) The communication targets voters in a particular election;


d) The communication identifies that candidate’s position on the public policy issue that is the subject of the communication;


e) The position of the candidate on the public policy issue has been raised as distinguishing the candidate from others in the campaign, either in the communication itself or in other public communications; and


f) The communication is not part of an ongoing series of substantially similar advocacy communications by the organization on the same issue.

Uh, gee. That sure SOUNDS like somebody broke the law for tax-exempt organizations.
It is, to be charitable, abuse — actually, abuse OF the charitable.*
[* Kinda like America At Its Best spending $4.8 million dollars in donations to qualify and advocate ballot initiatives in all those states, but listing it as”$4,834,168  on “RESEARCH AND EDUCATION REGARDING LIMITED GOVERNMENT IDEAS. “
America At Its Best ended the year with $8,731 and never filed another tax return, that good old Civic League and Social Welfare Organization. Just like volunteer fire fighters.]
You don’t suppose that any law enforcement in Chicago would take an interest in this, do you?
From Elizabeth Coulson for Congress (still up for the losing effort, but hurry):
Representative Coulson resides in Glenview with her husband Bill Coulson, a former Assistant U.S. Attorney, now a business, copyright and trademark litigation attorney with the firm of Gold & Coulson in Chicago.

Illinois State Rep. Elizabeth Coulson (R, Glenview)

Hey, but Americans for Limited Government is OUT of Illinois, remember?

Americans for Limited Government Fails to Meet Illinois Charity Requirements

WASHINGTON, D.C. December 19, 2006 — Americans for Limited Government, the Chicago-based tax-exempt organization chaired by New York political activist Howard Rich, has been forced to move out of Illinois because it could not comply with the state’s charity laws, the Center for Public Integrity reported today.

Americans for Limited Government spent at least $8 million in 2006 pushing “regulatory takings” initiatives and other ballot measures across the country.The organization faced public scrutiny in failing to disclose its donors or activities through a network of interconnected, tax-exempt entities. On Sept.15, Illinois Attorney General Lisa Madigan notified ALG that its registration under the state’s charitable solicitation laws was “delinquent and not in good standing” and would be canceled in 30 days if it failed to file a complete annual report, including an audit by a certified public accountant, as required by law.

Madigan sent identical warnings to ALG’s affiliate, Americans for Limited Government Foundation, but neither organization responded to the warnings, leading to the Illinois Attorney General’s office cancellation of their registrations as charitable organizations.

Rich recently was described by The Wall Street Journal as “a publicity-shy, libertarian-leaning businessman who has become the go-to man for supporters of conservative ballot initiatives.” Rich did not respond to the Center’s requests for information about ALG’s financial affairs.

ALG had operated from offices in Illinois since 2002, but just after the November 7 elections it quietly changed its address to the Virginia residence of one of its officers.* At the same time, ALG created two new tax-exempt groups, the Sam Adams Alliance and the Sam Adams Foundation, which occupy its former Chicago address.

[* That officer? William Wilson. You remember? The guy who signs their tax returns.]

Would it surprise you to know that the Sam Adams Alliance staffer Eric Odom “created” the first “tea party” organization (now, American Liberty Alliance) after that famous CNBC rant by Rick Santelli about how “he shouldn’t have to pay YOUR mortgage”?  Or this:

The American Liberty Tour is a collaborative project of the American Liberty AllianceAmericans for Limited Governmentand the Sam Adams Alliance.

Yeah. Those guys; guess they traded up for the Trojan Horse, again.

But the question is this: is anybody going to enforce campaign laws, or doesn’t anybody have to obey laws anymore?

Or was this “charitable” takedown of Beth Coulson a preview of what’s ahead with unlimited corporate campaign funding under whatever masks, shells and shills are necessary?

Or, worse, was this a preview of political campaigns for the rest of 2010?

Inquiring minds want to know.

Maybe even a few in Glenview, Illinois.



Note: PBS believes that Hart Williams was instrumental
in exposing the Howard Rich ‘gang’ in 2006.

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About Hart Williams

Mr. Williams grew up in Wyoming, Nebraska, Kansas and New Mexico. He lived in Hollywood, California for many years. He has been published in The Washington Post, The Kansas City Star, The Santa Fe Sun, The Los Angeles Free Press, Oui Magazine, New West, and many, many more. A published novelist and a filmed screenwriter, Mr. Williams eschews the decadence of Hollywood for the simple, wholesome goodness of the plain, honest people of the land. He enjoys Luis Buñuel documentaries immensely.

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