Thursday, May 31, 2012

501(c)s Avoid "Electioneering Communications" in Wake of Disclosure Decision

The Washington Post reports that the U.S. Chamber of Commerce will change it communication strategy to avoid "electioneering communications" - broadcast, cable, or satellite ads that clearly identify a candidate, reach a significant number of relevant electorate, and are run within a certain timeframe before the relevant election - while embracing express advocacy, that is ads that expressly support or oppose candidates.  The shift for the U.S. Chamber's planned $50 million of spending during the 2012 election cycle is driven by the recent federal district court decision in Van Hollen v. FEC, and the decision by the U.S. Court of Appeals for the District of Columbia Circuit not to stay the lower court decision pending appeal. 

The lower court decision rejected a Federal Election Commission promulgated regulation limiting the public disclosure of contributors to organizations making electionering communications to contributors who made their contributions for the purpose of furthering electioneering communications.  Instead, the court concluded the language of the relevant statute requires the public disclosure of all contributors (above a certain dollar threshold) to organizations that make electioneering communications, unless such organizations establish a separate segregated fund for making such communications and then all contributors (again, above a certain dollar threshold) to such a fund must be disclosed.  The decision does not, however, reach the rules for disclosing contributors to organizations that engage in express advocacy, which apparently is the basis for the U.S. Chamber's shift.  Other section 501(c) organizations are likely to follow suit, although many will probably avoid both electioneering communications and express advocacy altogether.  For more information, see the FEC summary of the case.  Law firm alerts regarding the decision are publicly available from Caplin & Drysdale (my former firm), Covington & BurlingHarmon, Curran, Spielberg & Eisenberg, and King & Spalding.


May 31, 2012 in Federal – Judicial, In the News | Permalink | Comments (0) | TrackBack (0)

May Recap - TBN's Allegedly Lavish Spending, Sandusky Charity to Close, and PILOTs in Providence

In the rush of end-of-term exam writing and grading, a couple of prominent nonprofit stories did not get covered during the past month:

  • NY Times Reports on Allegedly Lavish Spending by TBN:  Brought to light by an intra-family dispute, the article reports that the founders of Trinity Broadcasting Network, Paul and Janice Crouch, and some of their close family members have lived allegedly lived lavish lifestyles for decades in large part on TBN's dime.  Reported perks include multiple vacation homes, multi-million dollar corporate jets, thousand-dollar dinners, and lucrative deals with a company owned by family members. TBN, which is governed by a board of directors consisting only of the Crouches and one of their sons, denied through its lawyer any claims that the spending and other alleged activities were illegal or improper.


May 31, 2012 in In the News | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 30, 2012

What is a Religious Organization?

Over 40 Catholic organizations (including my employer, the University of Notre Dame) have filed coordinated lawsuits against the federal government challenging a regulation that would require the group health insurance sponsored by most employers to cover birth control and other services that are contrary to Catholic teaching.  See Notre Dame press release, the Washington Post blog entry.  One among the many interesting aspects of this dispute is the definition of a "religious employer," which is critical because group health plans sponsored by religious employers are exempt from the requirement.  As noted in the background section of a recently released Proposed Rule that the federal government is hoping will resolve this dispute,

a religious employer is one that (1) has the inculcation of religious values as its purpose; (2) primarily employs persons who share its religious tenets; (3) primarily serves persons who share its religious tenets; and (4) is a non-profit organization described in section 6033(a)(1) and section 6033(a)(3)(A)(i) or (iii) of the Code.

Since the first three prongs of the definition are relatively vague (for example, what are the thresholds for "primarily employs" and "primarily serves"?), arguably the narrowest part of this definition is the fourth prong that refers to two of the mandatory exceptions from having to file the Form 990 annual return otherwise generally required for organizations exempt from tax under section 501(a).  As the background section for the proposed rule elaborates, "[s]ection 6033(a)(3)(A)(i) and (iii) of the Code refers to churches, their integrated auxiliaries, and conventions or associations of churches, as well as to the exclusively religious activities of any religious order." 

Churches, and conventions or associations of churches, are of course religious organizations under section 501(c)(3) but many clearly religious organizations do not qualify as churches (or conventions or associations of churches) for federal tax purposes because "church" for these purposes is limited to organizations that generally have in-person worship meetings and other characteristics common to the historical, Western understanding of a "church."  See, e.g., the previous blog entry regarding the Foundation of Human Understanding case.  The definition of intergrated auxillary is more complicated, but in general an intergregated auxillary must be both affiliated with a church or a convention or association of churches and, most critically, be "internally supported," which is not the case if an organization offers admissions, goods, services or facilities (e.g., educational or health care services) for sale to the general public and recevies more than 50 percent of its support from a combination of governmental sources, public soliciation of contributiosn, and receipts from such sales.  See 26 C.F.R. 1.6033-2(h).  It is this last point that places the University of Notre Dame and presumably the other plaintiffs in these lawsuits outside of this exception. 

This dispute therefore highlights an increasingly important issue: assuming that for constitutional or policy reasons it is required or desirable to generally grant "religious" organizations exemptions from laws that would conflict with their religious beliefs, how broad should the definition of a "religious" organization be? Here the federal government has chosen a relatively narrow definition that was created for a different purpose (Form 990 filing exemptions), and at the end of the day it is the narrowness of this tax-based definition that has led to these lawsuits.


May 30, 2012 in Federal – Executive, Federal – Judicial, In the News | Permalink | Comments (0) | TrackBack (0)

Tuesday, May 29, 2012

Koch Brothers-Linked Nonprofit Made $55 Million in Grants to GOP-Allied Groups in 2009-10

The Los Angeles times reports that the Center to Protect Patient Rights granted more than $55 million during the 2010 election cycle to a range of GOP leaning groups without having to reveal the sources of its funds. The article notes several ties between the center and the Charles and David H. Koch, including that the Center is run by a GOP consultant who is "a key operative in the Kochs' political activities."  The Kochs, through a spokeswoman, declined to confirm or deny that they were involved with the Center, however.

According to its GuideStar description and its Forms 990 available through GuideStar, the Center is a section 501(c)(4) organization based in Phoenix, Arizona.  The Center's 2009 and 2010 Forms 990 list the grant recipients.  The groups receiving the most funds during this period were the American Future Fund, also a 501(c)(4), which received almost $13 million and the Sixty Plus Association, another 501(c)(4), which received over $11 million. 


May 29, 2012 in In the News | Permalink | Comments (0) | TrackBack (0)

IRS Revokes 501(c)(4) Exemption for Training Women for Party Leadership

In a series of almost identical determination letters, the IRS revoked the section 501(c)(4) tax-exempt status of five organizations with the stated purpose of identifying of women interested in potential leadership roles with a particular political party and the development of a political leadership training program for such women.  The IRS noted that each of the organizations is the affiliate of a national organization that shares the same purpose.  The IRS had previously recognized their exemptions but upon further study of their applications has now determined that these previous recognitions were in error because the groups primarily benefit private interests, specifically the interests of a particular political party and its candidates.  The IRS explicitly relied on American Campaign Academy v. Commissioner, 92 T.C. 1053 (1989), noting that while that case involved section 501(c)(3) "the standard for determining what constitutes private benefit described in American Campaign Academy applies to both [section 501(c)(3) and section 501(c)(4)]".  The rulings are 201221025, 201221026, 201221027, 201221028, and 201221029.

While the affected groups are, of course, not identified in the redacted rulings, the denial by the IRS last year of exemption for several similar training groups (see previous blog post) suggests these organizations may be related entities.  The NY Times identified those groups as state affiliates of Emerge America, which identifies, trains, and encourages (Democratic) women to run for office.  Interestingly, however, the more recent letters are much less redacted than the ones issued last year

If these five organizations are in fact additional state affiliates of Emerge America, that would probably explain why the IRS choose to take a closer look at their applications even after the IRS had approved those applications. Then again, this activity may simply reflect the decision by the IRS to look more closely at section 501(c)(4) organizations more generally (see previous coverage of the IRS v. Tea Party dispute).



May 29, 2012 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)

Friday, May 25, 2012

Mark Eustis Out at Fairview Following Accretive Scandal

Word out of Minneapolis is that Mark Eustis, the CEO of Fairview Health Services, has decided to step down following the revelations regarding the debt collection practices of Accretive Health that we blogged about a few weeks ago.   I sincerely hope, however, that Eustis' departure does not dissuade the IRS from revoking Fairview's tax-exempt status for violations of I.R.C. Section 501(r)(6) (and the community benefit standard of exemption in general).  Frankly, it's time to make an example of someone and send a clear message to the rest of the exempt health care industry that if they expect tax-exemption, they need to act like a charity, instead of just claiming to be one.


May 25, 2012 in Current Affairs, State – Executive | Permalink | Comments (0) | TrackBack (0)

Thursday, May 24, 2012

Congress Investigates Veterans Charity

With facts strikingly similar to those in the United Cancer Council case, the Disabled Veterans National Foundation is being investigated by the Senate Finance Committee to determine whether it should remain a tax-exempt charity under Section 501(c)(3) of the Internal Revenue Code.  According to a CNN article, its own investigation of the charity as part of "AC360's" "Keeping Them Honest" series led to the Committee's action on Wednesday.  According to CNN's review of the charity's records, only a small amount (reportedly as low as 2%-12%) of the approximately $56 million raised by the charity over the last 3 years has gone to directly assist veterans.  In that same period according to Forms 990, the Foundation paid nearly $61 million to a large direct-mail firm, Quadriga Art and its subsidiaries, which caters to nonprofits and charitable organizations.  CharityWatch, a large charity oversight organization, has awarded the Foundation an "F" grade since 2010 because of the small amount of fundraising dollars that actually reach veterans.

According to the CNN article, the Foundation joins more than 30 other charities tailored to veterans that have been given failing grades by CharityWatch due primarily to the small amount of expenditures actually spent on their veteran recipients.


May 24, 2012 in Federal – Legislative, In the News | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 23, 2012

PILOTs vs. Property Tax Reform

An interesting article/editorial in the New London, Connecticut newspaper, The Day, analyzing whether the region should consider comprehensive property tax reform and restructuring of local municipalities and services (i.e., going to a more regional structure on schools, fire and emergency services, etc.) rather than seeking payments in lieu of taxes (PILOTs).  It is an interesting discussion that is likely applicable to other local governments and taxing jurisdictions across the country.

Hat tip:  Nonprofit Quarterly


May 23, 2012 in In the News, State – Executive, State – Legislative | Permalink | Comments (1) | TrackBack (0)

Tuesday, May 22, 2012

Nonprofits' Failure to Report Fundraising Costs is Widespread

As reported by the Nonprofit Quarterly, a Scripps Howard News Service new study (utilizing data reported to the IRS and available through Guidestar) revealed found that 15,389 nonprofit groups, or 41% of all domestic nonprofits with annual receipts of $1 million or more, report on their annual Forms 990 that they expended no dollars on fundraising.  While this may be possible with respect to certain nonprofits, Scripps Howard did a further investigation, including interviews, which further revealed that a number of these zero-expense organizations actually do incur fundraising expenses but choose not to report them.  The percentage of nonprofits with zero reported fundraising costs varies greatly by state, with 60% or more of the nonprofits in the following states reporting no fundraising expenses:  Alaska, Arkansas, Idaho, Mississippi, and West Virginia (see a state ranking here).  As the study states, some nonprofit executives that were interviewed admitted that fundraising costs are nonreported or underreported to lower their nonprofits' overhead rates, which donors and funders use to rate nonprofits' efficiencies and effectiveness in achieving their purposes.

[See also an article in the Chronicle of Philanthropy]


May 22, 2012 in Federal – Executive, In the News, State – Executive | Permalink | Comments (0) | TrackBack (0)

Ways & Means Oversight Hearing - Increased Focus on Exempt Organizations' Activities

As reported by Rick Cohen in the Nonprofit Quarterly, in addition to topics blogged herein by Elaine Waterhouse Wilson (see Comments to blog entry), an interesting exchange occured between California Congressman Xavier Becerra and Catholic University Law Professor Roger Colinvaux.  In his testimony, Colinvaux commented that the focus of the law with respect to public charities is whether they are violating statutory and other prohibitions (what Cohen refers to as "negative requirements"), rather than the charities' actual activities in furtherance of their exempt puprose (i.e., "affirmatives").  Congressman Becerra, who is noted in the NQ article for focusing on public charities' outputs as the proper measure for tax exemption, subsequently suggested that the “nonprofit sector doesn’t do as much as it can to police itself.”  As Cohen states in the article, the Congressman was not referring to potential illegalities but rather the actual activities of charities in furtherance of their tax-exempt purposes. 

Professor Colinvaux's response was to propose a greater focus on charities' activities rather than merely their purposes.  He further proposed taking a fresh look at Section 170 and what qualifies for deductibility thereunder, as well as thinking about “whether there are some charitable purposes that should be prioritized over others.”  As Cohen notes in the NQ article, no other member of the panel supported or opposed the suggestion for refocusing and redefining priorities with respect to charities' activities and the support thereof from the charitable contributions deduction.  The article is an interesting discussion of the competing policies and priorities of tax-exemption law as it currently stands and potential tax reform in this area due to deficit reduction efforts and shrinking federal budgets.

For a more detailed analysis with respect to refocusing on charities' activities, Professor Colinvaux's article entitled, "Charity in the 21st Century:  Trending Toward Decay," is a must read (available here).


May 22, 2012 in Federal – Legislative, Publications – Articles | Permalink | Comments (0) | TrackBack (0)

NYT's "Room for Debate" - Should Churches Remain Tax-Exempt?

With particular relevance during this election season, the New York Times hosted another online "Room for Debate" entitled, "Should Churches Get Tax Breaks?"  This debate is composed of 5 pieces written by 6 persons (one is co-written) of differing backgrounds and viewpoints.  For those of us in legal academia, this can serve as a great platform for an interesting class discussion on the policy behind the tax exemption.  The five submissions are:

1.    Mark L. Rienzi, "Good for Religion, Good for America"

2.    Dan Barker, "Government Is Endorsing Religion"

3.    Winnie Varghese, "Sustaining Progressive Faith"

4.    Lawrence Sager & Christopher L. Eisgruber, "Don't Play Favorites"

5.    Susan Jacoby, "Equal Protection vs. 'Religious Freedom'"

Hat tip:  Nonprofit Quarterly


May 22, 2012 in Church and State, In the News | Permalink | Comments (0) | TrackBack (0)

Saturday, May 19, 2012

Alleged Conspiracy in the Rosa Parks Estate

This makes me sad. It's really hard to imagine more of an heroine than Rosa Parks, so it is upsetting that the footnote to her legacy is this ridiculousness. This conspiracy suit was apparently filed by the attorney that represented the Parks Foundation and one of its executives in prior probate proceedings, although it is never quite clear from the article as to whether he is filing on their behalf or on his own (I'm assuming this is just technically incorrect writing on legal matters but I could be wrong).

The petition alleges that the Court and the estate's appointed attorneys conspired to drain the estate of funds through attorney's fees and through the failure to enforce certain orders of the Michigan Supreme Court - a fairly serious (and difficult if not impossible to prove) charge. This article contains more background on the fight between the Parks heirs and the Parks Foundation and its co-founder.

I have to say that my first reaction was that I was stunned that the Foundation (if the Foundation is in fact the filer of the motion) would allege such a thing and whether that would serve to tarnish its repution. I suppose some of it will depend on the outcome.

Can anyone help me with access to the original petition? I'm not finding it right off, but will post a link if I can. Update: Here's a link to the petition.


May 19, 2012 in State – Judicial | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 16, 2012

Live Blogging the Ways and Means Oversight Hearing

So this is a bit of an experiment this morning. I'll be watching the streaming coverage of the Oversight Subcommittee of the House Ways and Means Committee Hearing on tax-exempt organizations, found at Thomas (here). According to what is scrolling on my screen right now, related documents will be available on the Committee's website once the hearing starts. It is giving this address for the documents - I'll try to link the full address when the committee goes live.

Below this post on the Nonprofit Law Prof Blog, you'll see there is a place for Comments. As the hearing starts, I'll be typing up my thoughts on the hearing in the Comments section to this post. Hopefully, that means they will be in order as the hearing goes on. I don't know if I have the ability to proofread the comments, so I'm going to beg your forgiveness right now for the typos that will occur.

I am going to get some more coffee and then let the experiment begin in about 10 minutes (10 EST)!


Update at 11:30 EST - hearing is over - see my comments below.

Boustany opening statement

October 6, 2011 letter from Boustany to Shulman

USHR09 Thomas Video

Witnesses written testimony

May 16, 2012 | Permalink | Comments (19) | TrackBack (0)

Tuesday, May 15, 2012

Ways and Means Hearing: The Cast Announced

Last week, Prof. Buckles let us know about the upcoming hearing to be held on Wednesday, May 16th courtesy of Rep. Charles Boustany Jr., Chairman of the Subcommittee on Oversight of the House Ways and Means Committee. At that time, the speakers were not yet announced, although it was noted that the witnesses were by invitation only. Given Rep. Boustany's recent activities in the tax-exempt area (such as investigating the tax-exempt status of AARP and questioning the IRS regarding the scope of its inquiries into certain Section 501(c)(4) exemption applications), I was admittedly skeptical about these hearings. The stated scope of the hearings is broad enough to encompass just about anything - including a foray into the political leanings of the IRS in the tax-exempt area. I was, as a result, some what relieved to see the list of speakers:

It's a fairly impressive and diverse list, so I'll be interested to see which way this hearing goes. I think there is still some room for the political discussion, but from this list it doesn't look like that should be the entire conversation. I'll be up tomorrow morning to try to watch it (and blog it!) so you don't have to.


May 15, 2012 in Federal – Legislative | Permalink | Comments (0) | TrackBack (0)

Friday, May 11, 2012

Peregrine on CEO Expense Accounts

Chicago lawyer Michael Peregrine of McDermott Will & Emery has written an opinion piece in the Chronicle of Philanthropy discussing questionable spending by a top administrator of a foundation benefitting the University of Texas Southwestern Medical Center.   In Why Watching CEO Expense Accounts Matters, Peregrine argues that adopting a few procedural safeguards can prevent spending missteps:

The first task is to craft workable guidelines for distinguishing business and personal expenses and identifying the appropriate business-related expenses for the chief executive’s spouse. The guidelines should also discuss how to account for and acknowledge donations to the charity from the CEO and how those will be reported for tax purposes.

Second, the nonprofit should create a system that makes it routine and easy for the board chairman to review expense-account spending. Auditors who work for the CEO can’t be the ones to raise the questions if something goes wrong; that is a board duty, and in some cases, one for the general counsel.

Boards should take action to step up their oversight of expense accounts, not solely out of concern with the CEO’s actual practices but also because it is a smart way to protect the institution and the office of its chief executive from scandal. CEO’s deserve effective guidelines from board leaders.

Peregrine concludes, “[B]oard chairmen have no choice but to make sure they are able to raise tough questions about personal spending even when that makes things uncomfortable for an otherwise outstanding chief executive.”


May 11, 2012 | Permalink | Comments (0) | TrackBack (0)

Galle Posts Paper on SSRN

Professor Brian Galle (Boston College Law School) has posted Charities in Politics: A Reappraisal on SSRN.  Here is the abstract:

Federal law significantly limits the political activities of charities, but no one really knows why. In the wake of Citizens United, the absence of any strong normative grounding for the limits may leave the rules vulnerable to constitutional challenge. This Article steps into that breach, offering a set of policy reasons to separate politics from charity. I also sketch ways in which my more-precise exposition of the rationale for the limits helps guide interpretation of the complex legal rules implementing them.

Any defense of the political limits begins with significant challenges because of a long tradition of scholarly criticism of them. Critics of the limits suggest that the “market failures” that justify tax subsidies for charity also afflict group efforts to monitor politicians and organize politically, so that the subsidy should extend to cover those activities. These claims, though, overlook a series of additional issues suggested by transaction cost economics and other aspects of economic theory.

Most significantly, even if lobbying and electioneering should be subsidized, it does not follow that these functions should be carried out by charities. I argue that combining politics with charity produces a set of diseconomies of scope, including higher agency costs, diminished “warm glow” from giving, and greater inframarginality of deduction recipients. In addition, I argue that the economically ideal tools for reaching the socially optimal levels of charity and lobbying are incompatible with one another. While there are also off-setting gains from the combination, many of these gains further exacerbate the diseconomies.


May 11, 2012 | Permalink | Comments (0) | TrackBack (0)

Thursday, May 10, 2012

Boustany Announces Hearing on Tax-Exempt Organizations

The Chronicle of Philanthropy reports that a congressional hearing will be held next week to examine various tax issues affecting nonprofits organizations.  Congressman Charles W. Boustany Jr., a Lousiana Republican and Chairman of the Subcommittee on Oversight of the Committee on Ways and Means, announced that the subcommittee’s hearing will be the first in a series of hearings on the tax-exempt sector and Internal Revenue Service oversight of tax-exempt activities.   The official announcement describes the focus of the hearing as follows:

The hearing will focus on certain current issues related to tax-exempt organizations, including the current IRS compliance initiative related to Universities, recently enacted reporting requirements for tax-exempt hospitals, recent efforts by tax-exempt organizations to design and implement good governance standards, and taxpayer involvement in redesigning the Form 990.  In addition, the hearing will discuss the history of recent legislative changes to the tax code dealing with tax-exempt organizations and what prompted those changes.

Those who are not scheduled for an oral appearance may still submit a written statement for consideration by the committee and for inclusion in the printed record of the hearing.


May 10, 2012 | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 9, 2012

Cuomo Proposes Changes in Regulating Care of Mentally Disabled

The New York Times reports that New York Governor Andrew Cuomo has proposed the creation of a new law enforcement and oversight agency to monitor people in state or private care who have developmental disabilities, mental illnesses, and other brain-related conditions.  The governor, says the story, is also calling for tougher punishment of those who abuse people with developmental or other cognitive disabilities. Part of Governor Cuomo’s proposal reportedly would directly affect nonprofit transparency by expanding New York’s Freedom of Information Law to require nonprofits that house publicly supported patients to make abuse and neglect records public:

Under the proposal, the public could submit requests for abuse and neglect records to nonprofit groups that provide residential or even daytime activity programs. The new state agency would provide the legal staff to help the nonprofit organizations respond to such requests and redact documents as needed.

The Times also states that Governor Cuomo, keeping in step with other states, “intends to establish an independent nonprofit organization that would serve as an outside advocate for those with disabilities and mental illnesses and that could bring litigation against the state.”


May 9, 2012 | Permalink | Comments (0) | TrackBack (0)

FCC Proposes to Lift Ban on Charitable Fundraising by Noncommercial Broadcasters

The Christian Science Monitor reports that the Federal Communications Commission (“FCC”) has proposed relaxing a rule that generally prohibits noncommercial public broadcast stations from raising funds for third parties.  The existing regulatory framework is said to rest on the premise that “stations must meet their educational mission to local communities through programming, not through fundraising for other organizations.”  However, the strictures of the current regulations reportedly have occasionally been waived by the FCC – as in the case of relief efforts for the families of 9/11 victims and for the victims of Hurricanes Andrew and Katrina – and religious and other noncommercial broadcasters have shown themselves capable actors in helping meet pressing needs when given the chance to do so.  According to the story, the new proposal would permit noncommercial stations to spend as much as 1 percent of their total annual broadcast time, or approximately 88 hours per year, conducting fundraising activities on behalf of nonprofit organizations. FCC Chairman Julius Genachowski  justifies the proposal in part as follows:

Given our experience …, where the ability to raise funds for third-party non-profits has been invaluable, we question whether it remains appropriate to require noncommercial stations to seek a waiver just as emergencies are occurring. This new FCC proposal would eliminate the need for such waivers and special requests.

Noncommercial broadcasters have long served the American public by providing high quality and innovative educational, cultural, and news programming to their local communities. By changing our ban against fundraising by public or religious broadcasters, the FCC can give them a chance to deepen their relationship with their communities, and heighten awareness about disasters at home and around the world.

Genachowski further characterizes the proposal as “another step in our ongoing efforts to modernize the FCC and eliminate unnecessary regulations.”


May 9, 2012 | Permalink | Comments (0) | TrackBack (0)

Tuesday, May 8, 2012

Quick Regulatory Update

Our friends at Treasury have been busy over the last two weeks, with two sets of regulations coming out in the charitable area:

1. Final Regulations Under Section 642(c). The IRS issued final regulations under Section 642(c) regarding the character of income for charitable lead trusts.

2. Additional Examples of PRIs under Section 4944. The IRS issued proposed regulations under Section 4944, adding a number of updated examples of "program related investments" for private foundations. Lots of good stuff in there.

I wanted to make you all aware these were out there - hopefully, more analysis later!


May 8, 2012 in Federal – Executive | Permalink | Comments (0) | TrackBack (0)