Friday, February 9, 2024

Feeding Our Future Continuing Fallout: A Guilty Plea, More Indictments, and New Counterclaims

6a00d8341bfae553ef0278806cd3f2200d-320wiThe U.S. Attorney's Office for the District of Minnesota announced last month that the executive director of House of Refuge Twin Cities pleaded guilty to one count of wire fraud in the $250 million fraud scheme centering on the nonprofit Feeding Our Future. The charge related to her redirection of millions of dollars in federal funds to pay personal expenses and family members. According to the press release, she is the seventeenth defendant to plead guilty to charges arising from this fraud scheme. Coverage: CBS News; Sahan Journal; Star Tribune.

And she is unlikely to be the last, as this week the same U.S. Attorney office announced federal criminal charges against 10 additional defendants arising from the same fraud (on top of approximately 60 already charged). Those defendants included six members from the same family who allegedly used a variety of legal entities to receive and launder the stolen federal funds, as well as four others who allegedly falsely claimed to have provided meals to children. Coverage: MPR News.

Not all the action is on the government's side, however. According to an MPR News article, the founder of Feeding Our Future and alleged leader of the fraud conspiracy is pushing back. She is asserting that Minnesota Department of Education officials who oversaw the hunger relief funds intentionally mislabeled document and used burner phones to improperly thwart a 2020 lawsuit brought by the nonprofit challenging the Department's treatment of Feeding Our Future. Her attorney stated that she plans to raise these allegations as part of her defense against federal wire fraud and bribery charges.

Lloyd Mayer


February 9, 2024 in Federal – Executive, Federal – Judicial, In the News | Permalink | Comments (0)

NCAA Update: NLRB Employee Ruling and NIL Rules & Disputes

DownloadThe Associated Press reports a National Labor Relations Board (NLRB) Regional Director has ruled that Dartmouth basketball players are employees, which would allow them to create a labor union. The decision is particularly significant because the players, in common with other Ivy League athletes, do not receive athletic scholarships  As the story notes, this holding is consistent with the NLRB General Counsel's 2021 memo concluding that certain college athletes should be considered employees. The decision is subject to review by the NLRB. Additional coverage: Inside Higher Ed; N.Y. Times; Slate; Washington Post.

Separately, in the rapidly developing name, image,  and likeness (NIL) area the Division I Council of the NCAA approved new rules relating to disclosure and transparency. The press release highlights "four elements of student-athlete protections": voluntary registration for NIL service providers; required disclosure by student-athletes to their schools of more than nominal NIL agreements; development of a template contract and recommended contract terms; and development of an education plan for student-athletes and other stakeholders. The Council also introduced new proposals for consideration relating to school involvement and recruiting in NIL activities, including ones that would remove certain restrictions on school support for such activities.

At the same time, disputes between the NCAA and schools relating to NIL arrangements are heating up. Last month the NCAA announced an agreement relating to a violation of NCAA rules by a Florida State assistant football coach, including various recruiting-related restrictions. Coverage: ESPN; Washington Post. And earlier this month USA Today reported a federal judge refused to issue a temporary restraining order relating to the NCAA's NIL rules in an antitrust lawsuit brought by Tennessee and Virginia. A preliminary injunction hearing in that case is set for next week.  Additional coverage: Law360 (subscription required). 

Lloyd Mayer




February 9, 2024 in Federal – Executive, Federal – Judicial, In the News | Permalink | Comments (0)

Tuesday, February 6, 2024

Ministry Watch: "Bankruptcy Case Forces Churches to Repay Hundreds of Thousands of Dollars in Donations"

Download (23)I previously blogged about a U.S. Bankruptcy Court decision that required a church to repay over $500,000 in donations. It turns out that a test case, as MinistryWatch reports that because of that result dozens of churches (including some that have settled) are required to repay donations they received. The donors were apparently shareholders in the now-bankrupt Health Diagnostic Laboratory of Richmond, Virginia.  And this is in addition to other, non-church charities from which the bankruptcy trustee is also seeking to recover donations. Critical to the court's holding was that the Bankruptcy Code section at issue does not allow the court to take into account potential hardship to a subsequent transferee, even if that subsequent transferee is unaware of the fraudulent nature of an earlier transfer.

Lloyd Mayer

February 6, 2024 in Federal – Judicial, In the News | Permalink | Comments (0)

Friday, January 19, 2024

Trifecta Follow-up to Title IX, NIL Collectives, and NRA Trial

This fine Friday, I have follow-up mini posts about all three of the things I blogged about this week: Title IX, NIL collectives, and the NRA trail. So, in reverse chronological order, here they are:

Yesterday, I wrote about the suit against Hillsdale college asserting that it was subject to Title IX regulation on account of its tax-exempt status. My colleague Darryll Jones alerted me to a press release from Senator Marco Rubio on Wednesday announcing proposed legislation to clarify that tax exemption is not “Federal financial assistance” for the purpose of Title IX. Obviously, if the legislation passes, that clarifies the law. But our legislative branch is not designed to easily pass legislation, and (it sure seems like) that the problem is worse these days, so I think it’s likely courts will probably have to make up their own mind what the original statute means.

On Wednesday, I wrote about NIL collectives, and got a very good series of questions from a commenter that I think are worth answering. A reader commented, “How do they determine the amount of the payments to avoid them being classified as excess benefit payments?  Do equal payments have to be paid to all players on the team?  How do you determine if one player's NIL is more valuable than another? I heard that Univ. of Texas is paying $50,000 to new football linemen; can they pay this to certain players and not to others?”

The answer to the first question is easy: “excess benefit” payments (if this is meant in its technical sense to refer to “excess benefit transaction” penalties in the Tax Code) occur between an organization and “disqualified persons” (people who have some level of control over the organization). Players are unlikely to be disqualified persons, so payments between NIL collectives and players will probably never be “excess benefit” payments. That’s why the question for NIL collectives is whether there too much private benefit, not whether there is any “inurement.” Honestly, if I were to try to identify the five most important things to understand about nonprofit law (for the students who take my introductory class, for example) this line between inurement and private benefit is definitely on the list, and so I can’t help point it out, even at the risk of fetishizing the phrase “excess benefit.”

But charities still have an obligation not to make excessively large payments to private persons who are not “disqualified persons,” notwithstanding the fact that “excess benefit” is technically the wrong word for such payments. As a state law matter, this obligation is found somewhere in the duty of care or the duty of obedience, the concept of “waste,” or in statutes that try to clarify this obligation. Some people (including the IRS) think that this duty is also reflected in the Federal-law concept of “excess private benefit.” Jurist Richard Posner famously proposed that idea (in dicta) in his opinion in the United Cancer Council case. This is also plausibly what the IRS means when it says that private benefit can be excessive either quantitatively or qualitatively. As I mentioned on Wednesday, Hail! Impact (the charitable NIL collective that has received IRS approval of tax-exempt status) solves the quantitative problem by only using 30% of its fund expenditures to pay NIL fees to athletes and uses the other 70% for truly charitable expenditures. But that 30/70 solution doesn’t solve the “qualitative” problem.

So, how should a charitable NIL collective make sure that it is not providing an excessive private benefit to athletes qualitatively through the wrong structure of its individual payments? The answer is: hard to know. The theory should be that it’s pretty safe if it pays them “fair market value” for the rights. That’s what American University (my employer, a charity) does when it decides how much to pay me. It tries to figure out what the market would bear, and then (if my economic theory serves me in this case) pays me the lowest it can get away with to keep me from jumping ship and to motivate me to do whatever it is that it wants me to do. So, as to the question of whether the NIL collective must (or can) pay the same amount to all players or must (or can) pay each player based on the value of their individual NIL, the default answer should be that it makes more sense to pay them based on an evaluation of their individual NIL value. But, of course, if the collective thinks that it can get away with paying all players the same amount, and if it thinks that’s good for the team or school, I can’t think of an argument for why that would violate the “private benefit” doctrine (or the directors’ state-law duty of care or obedience). But because the “qualitative” aspect of the private benefit doctrine is so under-developed as a legal matter, I’m not sure there is a clear answer to how it would apply in this case. Now that the IRS Chief Counsel’s office is focused on NIL collectives (as evidenced by the pretty quick and excellent Memorandum), I could imagine them using this opportunity to provide some guidance on their interpretation of the question. But, just like with Congress clarifying the scope of Title IX, I wouldn’t hold my breath. They’ve got a lot of other legitimate priorities, to say the least.

On Tuesday, I wrote about the expert testimony given by Jeffrey Tenenbaum in the NRA case. It was pointed out to me that there is some tension in what I wrote (that I wasn’t really aware of) about the purpose of Mr. Tenenbaum’s testimony: whether it was to establish “customary” practices among nonprofits or “best” practices. As I pointed out in the first paragraph, the court permitted his testimony about “what is regular and customary in the nonprofit sector.” But then in that same paragraph, I said he testified that “best practices” counsel against boards of more than 30 members because large boards make it “impossible [for individual board members] to fulfill their duties.” That’s a confusing quote because “best practices” is a quote of my source, NRA Watch, which said that “Tenenbaum said that best practices typically dictated an ideal non-profit board size of between 12 and 20 people.” But it did not quote him as using the term “best practices.” Instead it quoted him as saying that if a board has more than 30 people, it “becomes impossible [for individual board members] to fulfill your duties.” Anyway, in case it was confusing at all, I changed my own sentence in my final paragraph to clarify that I think it is valuable for juries to be educated about customary practices in the nonprofit sector, and that I’m glad Mr. Tenenbaum did that in this case. Although, obviously, it is still true that the jury will have to apply the legal standard, not whether NRA practices are “customary” or not.

Benjamin Leff

January 19, 2024 in Current Affairs, Federal – Judicial, Federal – Legislative, In the News | Permalink | Comments (0)

Thursday, January 18, 2024

Hillsdale College, Title IX, and the Charitable Contribution “Subsidy”

A recent Wall Street Journal opinion piece notified readers to a pending case against Hillsdale College by students who allege they were raped by classmates. The legal issue is whether Title IX -- the federal law that prevents sex discrimination in education -- applies to tax-exempt schools that do not receive federal funds. That’s the question that interest me. But I’m having trouble focusing on that issue because the WSJ piece is so weirdly inflammatory in its rhetoric that it is distracting. As tax professor Ted Seto pointed out in an email to the Taxprof Listserve, the claim (in the headline and first sentence of the piece) that the lawsuit is an “assault” on the college is absurdly hyperbolic.  Given that the plaintiffs are college students who allege they were raped by classmates at Hillsdale, the fact that the WSJ calls their lawsuit an “assault” on the college, despite the fact that they are trying to hold the school accountable for allegedly failing to meet minimum standards to protect them from harm, is to say the least distracting.  But, as they say, the WSJ Opinion Page will be the WSJ Opinion Page.

As for the substance of the legal issue, it’s actually quite important for nonprofit law generally, as well as being critical to the application of Title IX. Title IX is the federal law that governs sex discrimination in education. Congress wrote the law to apply to any “education program or activity receiving Federal financial assistance.” It does not apply to those that don’t. It is settled law that the “assistance” doesn’t have to go directly to the school, but that it is enough for the students who attend the school to receive them. What arguably is not settled is whether the fact that the school is exempt under section 501(c)(3) is sufficient by itself to constitute “Federal financial assistance.” On the one hand, there is a 2001 case out of the Northern District of Illinois called Johnny’s Icehouse, Inc., in which the court rejected the argument that the Amateur Hockey Association was subject to Title IX because of its tax exemption. It reasoned that Federal regulations define “Federal financial assistance” with a list of five enumerated types of assistance, none of which are the tax exemption provided in Section 501(c)(3) (to say nothing of the even juicier charitable tax deduction provided in Section 170). 34 C.F.R. 106.2(g). Since the regulations don’t define tax exemption to constitute Federal financial assistance for the purposes of law, the court held that it doesn’t.

On the other hand, there is a 2022 case out of the District of Maryland (currently on appeal to the Fourth Circuit) that holds the opposite. In that case, the court rejected a summary judgment motion by the defendant, who argued that Title IX didn’t apply to them because they receive no Federal financial assistance. The plaintiffs argued that tax exemption under section 501(c)(3) was sufficient financial assistance to subject the defendant school to Title IX, and the court agreed. It relied primarily on (very brief!) discussions of those two towering cases of the nonprofit law curriculum from 1983: Regan v. Taxation with Representation, 461 U.S. 540 (1983) and Bob Jones University v. United States, 461 U.S. 574 (1983). The court’s reasoning went something like this: (i) Taxation With Representation holds that tax exemption is a “subsidy;” (ii) in so holding, the Court said, “[a] tax exemption has much the same effect as a cash grant to the organization …;” (iii) Q.E.D., the fact that the Title IX regulations don’t specify that tax exemption is a form of financial assistance is not important because, “The Supreme Court has [recognized that tax exemption is] the equivalent of a cash subsidy.”

The problem with this reasoning is that it potentially opens up a can of worms in other areas of nonprofit law. At the heart of the theoretical foundation of all nonprofit law is the observation that tax exemption and the deduction for charitable contributions both acts as a subsidy and is different from other kinds of subsidies. It’s a subsidy that can be applied in a way that tries really hard to preserve the autonomy of the recipient from government control. That’s why it is a form of subsidy well designed for religious organizations, to take just one teensy example. Our Constitution prevents the government from establishing religion, which makes certain kinds of subsidies for religious organizations problematic. Because it is so broad and inclusive, the charitable tax exemption and contribution deduction serve the purpose of governmental support for religious organizations better in many instances than other types of more direct “financial assistance.” That’s true not just for religious organizations but in more instances than I could possibly list here.

With respect to actual question at hand – does Title IX apply to institutions that forego federal funds for themselves or their students – it seems to me that before deciding that based on the broad language of the Supreme Court about the equivalency of tax exemption and cash grants, I would want to know what Congress and/or the Department of Education think about the matter. By my reading, Congress’s choice of the phrase “Federal financial assistance” does not unambiguously include the concept of tax exemption. Therefore, the agency’s interpretation in regulations may be due some degree of deference (I know I know, everything I think I know about administrative law is either already wrong or will be by this time next year). In that case, I think a close reading of 34 C.F.R. 106.2(g) is warranted in this case. The operative question I think is whether Congress intended to apply Title IX to all schools that are tax-exempt? Or whether they intended Title IX to only apply to schools that accept some other kind of Federal financial assistance?

So, what is there to say about the pending lawsuit against Hillsdale College? First, the court will have to decide (without Sixth Circuit precedent) whether tax exemption alone constitutes “Federal financial assistance” sufficient to trigger the application of Title IX. In doing so, it has the reasoning of two sister district courts to aid its own analysis, one that applied a relatively narrow textual analysis of the Title IX regulations, one that reasoned in a broader way from principles announced in a 40 year old (but still great!) Supreme Court case. Obviously, I prefer the narrower analysis, although that doesn’t mean I necessarily know what that narrow analysis will produce in the suit against Hillsdale College. But also, while it is probably hyperbole to say (as Hillsdale’s president reportedly said) that a ruling for the plaintiffs on this issue would “sweep into the government’s net hundreds of thousands of American institutions that have sought to stay out of it,” it is also probably not completely untrue. Too many double negatives? Let me try again: I think that a ruling that relies on reasoning that tax exemption is the same as a cash subsidy in all cases is bad for nonprofit law. 

Benjamin Leff

January 18, 2024 in Church and State, Federal – Judicial, In the News | Permalink | Comments (0)

Wednesday, November 22, 2023

Founder of Christian Health Care Sharing Ministry Pleads Guilty to $8 Million Wire Fraud Conspiracy

6a00d8341bfae553ef02b751757181200b-320wiFollowing up on an earlier post that reported federal authorities had shut down section 501(c)(3) Medical Cost Sharing Inc., the U.S. Department of Justice has announced that the founder of this charity has pleaded guilty to conspiracy to commit wire fraud and making false statements on a tax return. According to the press release:

[Craig Anthony] Reynolds admitted that he and his co-conspirators used false and fraudulent promises to market Medical Cost Sharing as a “Health Care Sharing Ministry” to defraud hundreds of “ministry members.” Reynolds and his co-conspirators collected more than $8 million in member “contributions,” yet paid only 3.1 percent in health care claims so that they could personally profit and take most of the members’ contributions for themselves

Of course health cost sharing ministries do not automatically qualify for section 501(c)(3) status, for the reasons discussed in the recent IRS ruling discussed by fellow blogger Darryll Jones earlier this week. But this case highlights that even when they do appear to qualify, problems can still arise from their actual operations.

Coverage: KMBC; Medium.


November 22, 2023 in Federal – Judicial, In the News | Permalink | Comments (0)

UCLA Sues Mattel for Allegedly Failing to Make Good on $49 Million Pledge

Download (17)According to the L.A. Times (subscription required), UCLA and related entities have filed a lawsuit against Mattel for failing to make good on a 2017 pledge to donate $49 million to the UCLA children's hospital over 12 years. Mattel had previously given $25 million to support the children's hospital, in exchange for naming rights. While UCLA Health initially agreed to allow the company to suspend payments because of asserted financial issues, the company's profits in recent years and this year's Barbie movie success led to the lawsuit when payments did not resume. In defense, Mattel is asserting that the donation related to a new hospital tower that UCLA Health is no longer committed to building.

UPDATE: Thanks to fellow blogger Darryll Jones, I now have a link to the complaint in this case.

Additional coverage: CBS News; KTLA.

Lloyd Mayer

November 22, 2023 in Federal – Judicial, In the News | Permalink | Comments (0)

Church Ordered to Repay Over $500,000 to Bankruptcy Estate

W38s-level_origAs readers of this blog know, donations can bring with them a host of issues. These can include will disputes, naming rights conflicts, and of course donors seeking to perhaps unduly interfere with a charity's operations. The latter is illustrated by recent clashes between donors and universities relating to the Israel and Gaza; see, for example, the Philadelphia Inquirer story headlined  "Penn’s donor backlash raises questions about how much influence philanthropists should have" (subscription required).

A recent federal bankruptcy court case highlights another issue, and one that can result in the charity having to repay a major donation. In Arrowsmith v. First United Methodist Church Centre, Alabama (In re: Health Diagnostic Laboratory, Inc.), the Liquidating Trustee alleged to have traced between $550,000 and $850,000 as fraudulently transferred from the debtors to intermediaries and then from there to the defendant church (pictured here). After trial, the court ruled that the initial transfers were recoverable by the bankruptcy estate and that of those initial transfers $569,435 made its way to the church using accepted tracing methods.

Once that was proven, the main defense the church raised was an exception to recovery for a "transferee that takes for value, . . . in good faith, and without knowledge of the voidability of the transfer avoided." It was uncontested that the church had acted in good faith and without such knowledge, leaving the only open issue whether the church had provided anything of value in return for the funds it received. The church had issued the standard donation receipt stating it had not provided any goods or services in return for the donations, but the church argued that the donor had received intangible emotional benefits from contributing and, alternatively, that church members had provided (volunteer) services to  utilize the funds to further the churches charitable activities. The court found neither assertion demonstrated return value.

The church also argued that because it had spent the funds on its charitable activities, there were "changed circumstances" that should excuse the donations from recovery. However, the court noted that Congress has decided that the changed circumstances defense is not available when there has been a fraudulent convenience. The court also concluded the church could not invoke equity to allow this defense, since Congress had enumerated the available defenses.

Lloyd Mayer


November 22, 2023 in Church and State, Federal – Judicial | Permalink | Comments (0)

Monday, November 6, 2023

Proposed Class Action for Solicitation Fraud Filed Against LDS Church

Download (12)We previously reported about the August 2023 Ninth Circuit decision reinstating John Huntsman's claim against the Church of Jesus Christ of Latter Day Saints (more on that decision here) and the March 2023 survival in the face of a motion to to dismiss of a civil RICO claim against the LDS Church by another disgruntled donor. Now a different set of unhappy donors have filed a proposed class action against the LDS Church.

The thrust of their complaint is that the Church told them that their donations would be used immediately for charitable purposes, including "humanitarian relief," but instead some or all of their donations became part of a now multi-billion dollar endowment. The specific claims filed in the U.S. District Court in Salt Lake City include breach of fiduciary duty, fraud, and unjust enrichment. The docket is available on Pacer, but I have not been able to find a copy of the actual complaint that is not behind a paywall. 

Coverage: AP; Law360 (subscription required); NY Post.

November 6, 2023 in Federal – Judicial, In the News, Religion | Permalink | Comments (0)

Wednesday, October 11, 2023

Two Recent Court Decisions Highlight Charitable Contribution Deduction Abuse

Download (20)Download (9)Two unrelated federal court decisions last week demonstrate the creativity of individuals seeking to promote the abusive use of the charitable contribution deduction. One involved guilty verdicts in a massive syndicated conservation easement case and the other a default judgment on liability for marketing of an inflated valuation scheme.

The U.S. Department of Justice announced the guilty verdict with a press release titled Two Tax Shelter Promoters Found Guilty in Billion-Dollar Syndicated Conservation Easement Tax Scheme. Here are some details from the press release:

A federal jury sitting in Atlanta convicted Jack Fisher and James Sinnott today of conspiracy to defraud the United States, conspiracy to commit wire fraud, aiding and assisting the filing of false tax returns and subscribing to false tax returns. Fisher was also convicted of money laundering.

. . . .

According to court documents and evidence presented at trial, Fisher and Sinnott designed, marketed and sold to high-income clients abusive syndicated conservation easement tax shelters based on fraudulently inflated charitable contribution tax deductions, promising them deductions 4.5 times the amount the taxpayer clients paid.

. . . .

In total, the defendants sold over $1.3 billion in fraudulent tax deductions through this scheme.

Interestingly, a third defendant was acquitted. And it appears that the testimony of an accountant, who had previously pleaded guilty for his role in the scheme (likely the guilty plea reported here), was an important part of the government's case. It also appears that an appraiser who pleaded guilty earlier this year was involved in the same scheme.

The liability was found by a federal district court in American Properties, Co. G.P. v. The Welfont Group, LLC, et al. The plaintiff alleged that "it sold real property below market value based on Defendants' false representation that it would receive a substantial tax deduction for doing so." The plaintiff further alleged that the grounds for the deduction was to have been a purported qualified appraisal of $4,755,000 issued in connection with the plaintiff's sale of the property to a charity for $2,160,000, which the IRS determined was not a qualified appraisal and that was under any conditions undermined by an alter ego of one of the defendants immediately purchasing the property from the charity for $2,650,000. Because the defendants did not appear to defend themselves, the court entered a default judgment as to liability under several state causes of action based on the plaintiff's factual allegations. but declined to determine the damages amount (asserted by the plaintiff to be $1,321,013)  at this time as the plaintiff is still appealing the IRS' adverse determination against it on audit.

Lloyd Mayer

October 11, 2023 in Federal – Executive, Federal – Judicial | Permalink | Comments (0)

Monday, September 11, 2023

Politico Look at Ginni Thomas, Leonard Leo, Nonprofits and Citizens United

Politico had an extensively researched story looking at the history of Ginni Thomas and Leonard Leo and their association with nonprofits that have filed amicus briefs with the Supreme Court while directing money to Ginni Thomas.

From the story: "Two months before the Citizens United decision, but after the justices had signaled their intentions by requesting new arguments, attorney Cleta Mitchell — later to play a role in Donald Trump’s false claims about the 2020 elections — filed papers for Ginni Thomas to create a nonprofit group of a type that ultimately benefited from the decision. Leo was one of two directors listed on a separate application to conduct business in the state of Virginia. Thomas was president. She signed it on New Year’s Eve of 2009, and Crow provided much of the initial cash. A key Leo aide, Sarah Field, would come aboard to help Thomas manage the group, which they called Liberty Central.

After Liberty Central went public, it provoked an outcry over a Supreme Court justice’s wife promoting causes like overturning Obamacare that were before her husband’s court. Leo and Thomas changed gears. His network reactivated a dormant group, the Judicial Education Project, which would go on to become a major supplier of amicus briefs before the nation’s highest court. She created a for-profit consulting business using a similar name — Liberty Consulting — that enabled her to perform consulting work for conservative activist groups.

The Judicial Education Project supplied some of her business: Documents indicate Leo ordered at least one recipient of his groups’ funds, Kellyanne Conway, to make payments to Ginni Thomas for unspecified work, according to a Washington Post story earlier this year.

Now, Liberty Consulting is a focus of interest from congressional committees probing the Supreme Court’s ethics disclosures. Senate Democrats have demanded that Leo and Crow provide a list of “gifts, payments, or other items of value” they’ve given Thomas and her husband."

"Together, the probes have combined to raise the question of whether Leo’s groups have taken advantage of lax disclosure laws to send additional business and funds to Ginni Thomas, among other activists. That would be legal as long as Thomas was providing services commensurate with the payments."

Philip Hackney

September 11, 2023 in Current Affairs, Federal – Judicial | Permalink | Comments (0)

Thursday, August 3, 2023

University of Chicago Obtains Partial Summary Judgment in Dispute With Pearson Foundation

6a00d8341bfae553ef022ad37e280a200d-320wiAfter more than five years of litigation - see previous coverage of the initial complaint and the federal district court's partial grant of a motion to dismiss - between The Thomas L. Pearson and The Pearson Family Members Foundation (and Thomas Pearson individually) and the University of Chicago, we have a ruling on the cross motions for partial summary judgment (2023 U.S. Dist. LEXIS 131701; 2023 WL 4868559). In a lengthy opinion dated July 31, 2023, the U.S. District Court for the Northern District of Oklahoma denied the plaintiffs' motion and granted the defendant University's motion in part.

The dispute arose over a $100 million grant to the University for The Pearson Institute for the Study and Resolution of Global Conflicts pursuant to a detailed Grant Agreement. According to the court, the Foundation and Mr. Pearson in an amended complaint asserted five claims: "(1) breach of contract, (2) breach of the duty of good faith and fair dealing, (3) fraudulent inducement, (4) unilateral mistake, and (5) equitable rescission." (The court in 2018 dismissed claims of breach of fiduciary duty and fraudulent concealment that had been stated in the initial complaint.) The court granted the University summary judgment on certain aspects of the breach of contract claim , on the unilateral mistake claim, and with respect to the plaintiffs' request for punitive damages (as well as striking one aspect of the breach of contract claim as being beyond the scope of the court-granted leave to amend the complaint). The remaining aspects of the breach of contract claim, along with the three other remaining claims, will now presumably proceed to trial, absent a settlement.

Lloyd Mayer

August 3, 2023 in Federal – Judicial | Permalink | Comments (0)

Thursday, May 25, 2023

How to Not (and Maybe How To) Make Money Off of Tax-Exempt Political Organizations

Download (13)Late last month, the U.S. Department of Justice announced the sentencing of three individuals "for soliciting millions of dollars in contributions to scam PACs." The press release further states:

According to court documents, from 2016 through at least April 2017, Tunstall, Reyes, and Davies operated two PACs – Liberty Action Group PAC and Progressive Priorities PAC – that solicited contributions from the public via robocalls and radio and internet advertisements. The two PACs represented that the contributions would be used to support the presidential nominees of the two major political parties, respectively.  Instead, the co-conspirators used the funds to enrich themselves and to fund additional fraudulent solicitations. Specifically, the two PACs raised approximately $4 million in contributions during the 2016 election cycle and subsequent months.

The penalties for this deception? A sentence of 10 years in prison, a sentence of 7 years in prison, and a sentence of 5 years of probation. Additional coverage: CNN.

As previously discussed in this space, the N.Y. Times recently had a lengthy story about five other tax-exempt political organizations that reportedly raised almost $90 million while only spending $800,000 on actual political activity. Yet that story indicates the four of those organizations still in existence have so far survived IRS scrutiny of their operations in the form of examinations that began a year or so ago. It remains to be seen whether this high profile coverage will lead to more critical IRS, and perhaps DOJ, attention.

I have not done a deep dive into the documents detailing the finances of either set of groups, but the key difference may be that the money flowing out of the tax-exempt section 527 organizations has to at least arguably go to outside vendors for actual services rendered, even if those services are mostly generating additional fundraising appeals.  Of course the fact that those vendors have financial connections to the individuals who also run the tax-exempt organizations sets off alarm bells, but that fact by itself does not make the payments illegal. And the organizations also have to be careful what is actually said in the irappeals for donations, as making specific promises to potential donors that are not kept is also problematic.

This last point is demonstrated by the recent sentencing of two individuals involved in the tax-exempt section 501(c)(4) organization "We Build The Wall" fundraising effort to 51 and 37 months in prison, respectively. The court also ordered that those individuals pay millions in restitution. In that case, one individual promised that he would  “not take a penny in salary or compensation” and that “100% of the funds raised…will be used in the execution of our mission and purpose.” In fact, the individuals involved directed for their personal benefit and use hundreds of thousands of dollars out of the more than $25 million raised.

Lloyd Mayer

May 25, 2023 in Federal – Executive, Federal – Judicial, In the News | Permalink | Comments (0)

Tuesday, April 18, 2023

Tax Law Center at NYU Files Brief in Buckeye Institute v. IRS

The recently formed Tax Law Center at NYU filed an amicus brief in the district court case of Buckeye Institute v. IRS. The Buckeye Institute has challenged the constitutionality of the IRS collecting substantial donor information on the Form 990.

From the Tax Law Center: "The Tax Law Center filed this amicus brief supporting the government’s motion to dismiss in The Buckeye Institute v. IRS. The case involves a constitutional challenge to a federal statute that has existed for more than 50 years—the requirement that charitable organizations identify their major donors in their federal tax filings if they wish to receive the benefits of tax-exempt status under section 501(c)(3) of the Internal Revenue Code. The Tax Law Center’s brief explains why this reporting requirement directly advances the government’s interest in revenue collection. As the brief concludes: “A finding that the requirement is unconstitutional would directly undermine the federal tax base and would threaten the integrity of the tax system. The requirement is crucial to the federal government’s revenue collection efforts, and it should be upheld in its entirety.” 

You can read the brief here.

Philip Hackney

April 18, 2023 in Federal – Judicial | Permalink | Comments (0)

Tuesday, April 4, 2023

Another Federal District Court Concludes the TEGE Commissioner Can Approve Church Tax Inquiries

2019-01-09While we continue to wait for Treasury to finalize the proposed regulations issued in 2009 (!) under Internal Revenue Code 7611 , churches subject to IRS church tax inquiries continue to challenge the approval process for those inquiries. Late last month, another federal district court concluded that the IRS Tax Exempt and Government Entities (TEGE) Division Commissioner is a sufficiently "high-level Treasury official" to approve such inquiries under that section. In God's Storehouse Topeka Church v. United States, the U.S. District Court for the District of Kansas rejected the church's arguments that only a higher official - either the Deputy Commissioner for Services and Enforcement or perhaps only the Commissioner or Treasury Secretary - are of high enough rank. In doing so, the court relied heavily on the reasoning that led to the same conclusion in United States v. Bible Study Time, Inc., 295 F.Supp.3d 606 (D.S.C. 2018). The court also rejected other objections to the IRS' third-party summons in the case.

Hat Tip: EO Tax Journal.

Lloyd Mayer

April 4, 2023 in Church and State, Federal – Judicial | Permalink | Comments (0)

One Civil RICO Claim by LDS Donor Survives Motion to Dismiss in Federal District Court

Download (5)Late last month, the U.S. District Court for the District of Utah issued an opinion in a lawsuit brought for a former member of and donor to the Church of Jesus Christ of Latter-Day Saints. In Gaddy v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, the court dismissed almost all of the plaintiff's claims stated in an amended complaint on a variety of grounds, including that some of them would have required the court to inquiry into the truth of the Church's religious teachings and doctrines (which was the primary basis for dismissal of the plaintiff's original complaint as well). But a civil RICO claim survived for the following reasons, as stated in the court's opinion:

As alleged in the Amended Complaint, the court concludes Gaddy's third alternative civil RICO theory is based on a secular dispute concerning statements by Church leadership about the specific ways tithing, once received, would in fact be spent. . . . .

Here, Gaddy does not challenge the Church's tithing doctrine or teachings related to it. The court does not read her Amended Complaint to advance a claim that the doctrine is false. Gaddy instead points to specific factual statements allegedly made by the Church through its representatives concerning the Church's use of tithing funds and alleges those statements are false. The inquiry required to adjudicate this claim does not implicate religious principles of the Church or the truth of the Church's beliefs concerning the doctrine of tithing. This claim further does not require the court to determine whether the Church or its members were acting in accord with what they perceived to be the commandments of their faith. Gaddy has instead challenged secular representations concerning the use of money received by the Church. While the statements were made by Church officials, the church autonomy doctrine does not apply as a defense. The Church has not asserted any other challenge to Gaddy's RICO claim based on this alternative theory of liability. Accordingly, Gaddy's RICO claim based only on this alternative theory survives the Church's Motion to Dismiss.

The court also granted the plaintiff leave to further amend her complaint.

Lloyd Mayer

April 4, 2023 in Federal – Judicial | Permalink | Comments (0)

Federal District Court Affirms Bankruptcy Court's Approval of Boy Scouts Settlement

Download (10)The Boy Scouts of America (BSA)'s comprehensive reorganization plan and global settlement of sex abuse claims continues its slow march through the federal judicial system. Late last month, the U.S. District Court for the District of Delaware affirmed the U.S. Bankruptcy Court's previous approval of a reorganization plan that provides $2.46 billion to settle sex abuse claims against the BSA, over the objections of some insurance companies and abuse claimants. While the opinion is lengthy (156 pages), here is the District Court's bottom line:

Appellants argue on many fronts that the Plan did not meet requirements for confirmation, and I have carefully considered each of these arguments. Based on the record, Appellants have failed to put forth evidence that would demonstrate clear error in the Bankruptcy Court's careful findings of facts. Finding no error in the Bankruptcy Court's legal conclusions either, I will affirm the Confirmation Order.

Coverage: Reuters.

Lloyd Mayer

April 4, 2023 in Federal – Judicial, In the News | Permalink | Comments (0)

Monday, March 6, 2023

Conservation Easements Update: Cert. Denial; Hearing on Proposed Regs; New Articles

6a00d8341bfae553ef02a2eecbab26200d-320wiThe long legal grind relating to conservation easements continues, with no end in sight. Setting aside the periodic issuance of dispositive and procedural decisions in the many pending cases - about half-a-dozen such decisions over the past three or so months by my count - there have been two significant developments and two new articles of interest.

First, the Supreme Court of the United States denied certiorari in Oakbrook Land Holdings, LLC v. Commissioner, one of two federal appellate court decisions that had created a circuit split over the validity of a conservation easement regulation. The Court apparently took to heart Professor Michael Kane's recommendation that it not take up this issue.

Second, the Treasury Department held its public hearing earlier this month on proposed regulations designed to address court decisions holding syndicated conservation easement listing Notice 2017-10 to be invalid under the Administrative Procedure Act. According to a Thompson Reuters article, many commentators urged Treasury to retain a carveout for donee organizations. According to a Law360 article, some of the commentators also questioned whether the proposed regulations are needed now that Congress has enacted a new charitable deduction disallowance rule for certain conservation easement contributions. 

As for the articles, Vanderbilt Law Review has published a note authored by Molly Teague and titled Conservation Options: Conservation Easements, Flexibility, and the “In Perpetuity” Requirement of IRC § 170(h). And the Wildlife Society Bulletin published a short article by several scholars titled Conservation Easements: A Tool for Preserving Wildlife Habitat on Private Lands and proposing "a shift from primarily negative clauses and restrictive language to a more affirmative approach, developing language to proactively improve management of properties under conservation easement in order to maximize benefits to wildlife and ecosystems."

Lloyd Mayer 


March 6, 2023 in Federal – Executive, Federal – Judicial, Publications – Articles | Permalink | Comments (0)

Monday, February 13, 2023

Varsity Blues and Corner Boys: Defending The 568 Cartel

Watch The Wire Season 4 Episode 1 Online - Stream Full Episodes

Corner boys, The Wire

Twenty years ago, HBO premiered a gritty urban drug crime drama set in B'more called The Wire.  It focused primarily on corner boys -- the small fry hustlers, the inner city version of last mile delivery in a long distribution chain.  The corner boys retailed pharmaceuticals from local retail shops set up at strategically located corners.  They were rich relative to overall wealth of the neighborhood.  They always had nice jeans, gold or silver jewelry and brand new Nikes or Lugs.  Of course the real wealth resided uptown -- Guilford, maybe -- at the start of the distribution chain.  More on that later. 

In other news it looks like its all over but the crying in the Varsity Blues scandal.  The mastermind, Rick Singer got 42 months for selling access to prestigious colleges and universities.  Felicity Huffman and a few less well known wealthy moms and dads received from 2 to four months in jail.   Lots of coaches got fired, too.  If what Rick Singer and the coaches were selling were drugs, rather than admission to highly selective universities, they would have been corner boys.  And if Rick and the coaches were corner boys, who would have been the kingpins, the ones getting rich at the start of the distribution chain?


Henry v. Brown University, et. al, an antitrust case working its way through the  Northern District of Illinois, pretty much identifies the elite colleges themselves as the kingpins.  At the same time, the complaint call into question whether those universities adequately serve the less wealthy.  DOJ is on the side of the plaintiffs.  And you can view all the pleadings and lots of media coverage here at plaintiff's counsel's website. 

For now, here is the long and short of it:  Colleges and Universities have, for about the past 20 years, enjoyed an antitrust exemption (the 568 exemption, which was allowed to sunset late last year) allowing them to fix prices by forming what the plaintiffs smartly label the "568 Cartel," But the exemption required the kingpins implement and adhere to need-blind admission policies.  Need blind admission policies means colleges can't give preferences to wealthy parents or donors in the hopes that admitting those students will lead to more big donations.  The complaint makes a serious case -- with many examples -- that elite universities, especially, practice affirmative action for the wealthy by giving rich kids preference.  Some of the universities even implement "separate and equal" admissions procedures for children of wealthy donors.  Here are a few snippets from the 61 page complaint (which has survived an onslaught of motions to dismiss):

1. Defendants are private, national universities that have long been in the top 25 of the U.S. News & World Report rankings for such schools. These elite institutions occupy a place of privilege and importance in American society. And yet these same Defendants, by their own admission, have participated in a price-fixing cartel that is designed to reduce or eliminate financial aid as a locus of competition, and that in fact has artificially inflated the net price of attendance for students receiving financial aid. Defendants participate in the cartel claiming the protection of Section 568 of the Improving America’s Schools Act of 1994 (the “568 Exemption”). This exemption from the antitrust laws, which otherwise prohibit conspiracies among competitors, applies to two or more institutions of higher education at which “all students admitted are admitted on a need-blind basis.” Section 568 defines “on a need-blind basis” to mean “without regard to the financial circumstances of the student involved or the student’s family.” 

2. Defendants have not been entitled to the 568 Exemption. Under a true need-blind admissions system, all students would be admitted without regard to the financial circumstances of the student or student’s family. Far from following this practice, at least nine Defendants for many years have favored wealthy applicants in the admissions process. These nine Defendants have thus made admissions decisions with regard to the financial circumstances of students and their families, thereby disfavoring students who need financial aid. All Defendants, in turn, have  conspired to reduce the amount of financial aid they provide to admitted students. This conspiracy, which has existed (with slightly varying membership) for many years, thus falls outside the exemption from the antitrust laws.

3. Defendants are members of the so-called “568 Presidents Group,” in which the members have agreed on “a set of common standards for determining the family’s ability to pay for college,” which the members describe as the “Consensus Approach.” Based on the Consensus Approach, in approximately 2003 the 568 Presidents Group (the “568 Cartel”) devised the Consensus Methodology, which is a common formula for determining an applicant’s ability to pay. Under the Consensus Methodology, an applicant’s ability to pay is a substantial determinant of the net price, which is the institution’s gross tuition plus fees for room and board, less institutional grant aid, charged to the applicant for attendance.

5. Defendants’ longstanding conspiracy would be immune from the antitrust laws only if they have all been complying with the 568 Exemption. In fact, however, at least nine Defendants (Columbia, Dartmouth, Duke, Georgetown, MIT, Northwestern, Notre Dame, Penn, and Vanderbilt) have been members of the 568 Cartel and have not qualified for the 568 Exemption throughout the Class Periods (defined below).

Essentially, the complaint alleges that the universities were never entitled to fix prices because they were hardly charitable, as that term relates to serving all without regard to wealth.  I am not an antitrust expert, but I imagine price fixing hurts the poorest consumers the most.  Which makes me wonder why Congress would ever sanction price fixing amongst charities. If the universities were honest (naturally they deny it all), they would argue that giving a relative few super wealthy people preference helps the charitable mission, even if the preference disadvantages a few less wealthy people,.  Then we could have a serious debate acknowledging both sides of the issue.  The private benefit to the super wealthy advantage so many other less wealthy people that its worth the trouble.  Here is what I thought of to help me think of a plausible justification:

Suppose a soup kitchen had enough soup to feed ten hungry people per day.  People queue every day for soup and every day at least five people don't eat because the kitchen runs out of soup.  Every once in awhile, the 10th person -- Number 10 -- is passed over in favor of somebody behind her.  The unlucky Number 10 that day doesn't eat.  It doesn't matter that Number 10 worked harder, waited in line longer, or was otherwise more legitimately deserving of soup that day.  The person given preference -- Number 11 -- is someone who needs the soup and has lots of other assets that can help the soup kitchen feed more people per day.  It doesn't really matter that Number 11 didn't work as hard, woke up late and got in line late.  Because if Number 11 gets soup today, she may donate some of her other wealth to the kitchen and the kitchen will be able to increase the amount of soup available to 15 bowls a day maybe.  The average number of hungry people per day decreases dramatically.  Ultimately, the increase in charitable outreach -- from 10 to 15 bowls of soup per day -- outweighs the private benefit inuring to the preferred person able to afford to get to the front of the que, or at least ahead of number 10.     

So it might be knee-jerk to condemn the universities or the soup kitchens.  Maybe we can tolerate a little private benefit today, for much more public benefit tomorrow.  We should think this through because Rick and the coaches were just corner boys.    


darryll jones

February 13, 2023 in Federal – Judicial | Permalink | Comments (0)

Friday, February 10, 2023

Tik Tok, Chinese Exclusion, and Charitable Tax Exemption


@johnleehooker Happy Friday, folks. Here’s John Lee performing “Crawlin' King Snake'' with Ry Cooder on the BBC show 'John Lee Hooker And Friends.' #JohnLeeHooker ♬ original sound - John Lee Hooker

John Lee Hooker hums the blues.   

Here are the first two sections of the infamously racist Chinese Exclusion Act:

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That from and after the expiration of ninety days next after the passage of this act, and until the expiration of ten years next after the passage of this act, the coming of Chinese laborers to the United States be, and the same is hereby, suspended; and during such suspension it shall not be lawful for any Chinese laborer to come, or having so come after the expiration of said ninety days to remain within the United States.

SEC. 2. That the master of any vessel who shall knowingly bring within the United States on such vessel, and land or permit to be landed, any Chinese laborer, from any foreign port or place, shall be deemed guilty of a misdemeanor, and on conviction thereof shall be punished by a fine of not more than five hundred dollars for each and every such Chinese laborer so brought, and maybe also imprisoned for a term not exceeding one year.

There has been no other time in American history that we have excluded a whole race of people from our shores, except perhaps through de facto measures employed at various times of panic.  In light of this history, we ought to take a good hard look in the mirror before we start targeting Chinese companies.  Just to make sure we are competing legitimately against the biggest dog in the geopolitical realm, and not from irrational fear like that leading to Exclusion Act.  And yes, I know that some Chinese kid's tandem tractor-trailer sized birthday balloon floating across the heartland (taking pictures of American backyard birthday parties, no doubt!) does not make easier our efforts to be rational.  But we should remember that speech has consequences and as we constantly and continually make the word "China" and anything "Chinese" a pejorative, we unwittingly and with imperception put targets on the backs of little old Asian ladies walking to the grocery store.  And then some crazy despicable coward strikes, thinking nobody will care because these are our "enemies" anyway.  

I try -- in my increasingly desperate attempts to generate clicks on this blog -- to get at least a little background on the underlying topic of every post.  I haven't read "Slaying the Global Coolie Myth" but it sounds very interesting.  I just wish I had time.  Here is just a snippet from Oxford University Press (scroll down to the tax stuff if you want me to shut up and get to the charities):

"Contrary to stereotypes of docile and powerless coolies, Chinese in Anglo-American societies were real people who worked hard, adapted, and persisted” So reads the caption to the final photo in Ngai’s magisterial work on global Chinese exclusion. It articulates the central theme of the book: that Chinese migrants had names, families, and communities of their own.

In tracing how the Chinese Question began in California and “circumnavigated the Anglo-American world,” Ngai demonstrates how debates over the ability of Chinese to enter and access rights in the world’s three “largest gold-producing regions”— the United States, Australia, and South Africa—were “an integral part” of the “global capitalist economy” that was emerging in the nineteenth and early twentieth centuries. The discovery of gold fueled the rise of U.S.-UK dominance; according to one statistic, the United States and Great Britain controlled eighty-eight percent of the world’s gold supply by 1904. Ravaged by the Opium Wars and unequal treaties, China engaged from a position of comparative weakness. Out of a convergence of economic dominance, colonial dispossession, and global racisms, the Chinese diaspora in the Anglo-American world was born. Questions of how to contain and control it arose immediately, and the coolie myth presented an answer.


I am on my soapbox today about the DITCH Act, a recent proposal sponsored by Sen. Josh Hawley and Rep. Gallagher mandating nonprofit divestment from Tik Tok and others like it.  And before you dismiss the effort as unlikely, just know that there is nothing more bipartisan in Congress today than a hatred of Tik Tok and many more things Chinese.   This proposal isn't just some crazy election denying, back bencher calling the President a liar . . . . during the SOTU, on national and international TV.  The bill has a good chance of being swept along with the other anti-Chinese sentiments stoked, but not validly provoked by Tik Tok, COVID, and balloons.  On the bright side, though, proposed 501(s) is full of wonderful, intricate, regulatory- and fee-generating complexity so there's that.  A veritable feast for the eyes:  


‘(1) IN GENERAL.—An organization shall not be treated as described in subsection (c) or (d) or section 401(a) for any taxable year if such organization —

‘(A) holds any interest in a disqualified Chinese company at any time during such tax-able year, or

(B) fails to timely transmit the annual report described in paragraph (5) for such taxable

(2) DISQUALIFIED  CHINESE  COMPANY.—For purposes of this subsection—

(A) IN GENERAL.—The term ‘disqualified Chinese company’ means any corporation—

(i) that is incorporated in China, or

(ii) more than 10 percent of the stock of  which (determined by vote or value) is held (directly or indirectly through any chain of ownership) by any of the following (or combination thereof):

(I) 1 or more corporations described in clause (i).

(II) China or any governmental agency

(III) Provincial,  regional,  municipal, Special  Administrative Regions, prefecture, county, township, village, or any other Chinese sub-national governmental entity or

(IV) Any entity controlled (directly or indirectly) by the Chinese Communist Party or any Chinese Communist Party

(V) Any Chinese National 

(B) APPLICATION TO ENTITIES TO OTHER THAN CORPORATIONS.—In the case of any business organization which is not a corporation, subparagraph (A) shall apply to such organization in the same manner as though such organization were a corporation.

(C) APPLICATION TO INDIRECT DERIVATIVE, OR OTHER CONTRACTUAL INTERESTS, ETC.—For purposes of this subsection, an organization shall be treated as holding an interest in a disqualified Chinese company if such organization—

(i) holds such interest (or any instrument described in subparagraph (A)) directly or indirectly through any chain of ownership, or

(ii) holds any derivative financial instrument or other contractual arrangement with respect to such interest or company (including any financial instrument or other contract which seeks to replicate any financial return with respect to such interest or such company).

Here is the PR announcing the measure late last year:

Today U.S. Senator Josh Hawley (R-Mo.) and Congressman Mike Gallagher (R-Wisc.) introduced the Dump Investments in Troublesome Communist Holdings Act (DITCH Act). The new legislation requires university endowments, public pension plans, and other entities exempt from federal income tax to divest their investments in Chinese companies or lose their tax-exempt status.

Senator Hawley said, “Universities, foundations, and other entities are exempt from federal income tax for their work promoting the public good in the United States. Investing in China does the opposite: it advances the economic ambitions and military modernization efforts of the Chinese Communist Party while selling out American workers and values. These tax-exempt entities must stop investing in China or lose their tax-exempt status.”

"Tax-exempt entities that invest in CCP-directed companies are not only profiting off of genocide, destroying the environment, and financing the PLA's ability to build weapons that can kill Americans, but are also making U.S. taxpayers unwittingly subsidize it. This has to stop," said Congressman Gallagher. "Any entity that receives preferential tax treatment must make a choice: are they committed to their professed values, or are they committed to financing a genocidal communist regime and its malign efforts around the world? If a tax-exempt entity chooses to continue to sell out its own country for a small slice of the Chinese market, then they must lose their tax-exempt status."

To combat threats posed by investments in China, the DITCH Act would:

    • Prohibit entities exempt from federal income tax from investing in Chinese companies. Tax-exempt entities that do not divest investments would lose their tax-exempt status.
    • Allow the Treasury Secretary to grant a waiver to certain tax-exempt entities if they detail why their need for holding Chinese assets outweighs the national security risk.
    • Require the Treasury Secretary to publish a report within 360 days and then annually thereafter detailing outbound investment into the Chinese market.

Actually, this whole post is tax stuff.  That's why I like taxation.  Since it intrudes upon every aspect of life, from birth to death, marriage and divorce, kids, going to work, starting a business, or immigration or emigration, tax is the door to intellectual renaissance.  So read your tax code everyday, boys and girls!


darryll jones

February 10, 2023 in Federal – Judicial | Permalink | Comments (0)