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July 20, 2004
GOP ticket seeks church membership lists
Providing names to campaigns raises ‘red flags,’ IRS officials say
by Daniel Burke
Religion News Service
WASHINGTON — Internal Revenue Service officials say churches that provide membership lists to political campaigns may be in violation of federal regulations.
IRS officials said during interviews on July 15 that, if church lists are given to only one campaign, the congregation could lose its tax-exempt status. Moreover, those who give away lists worth more than $1,000 could be required to register with the Federal Election Commission.
IRS regulations forbid non-profit organizations such as churches from giving their mailing lists to partisan political campaigns unless the campaigns pay for them.
And a church directory qualifies as a “mailing list,” according to Joseph Urban, a manager in the exempt-organizations division of IRS.
July 15 was designated by the Bush‑Cheney campaign as a day for churches to host “coffee/pot luck dinners” in support of the GOP slate.
Urban said potential violations of IRS regulations are handled on a case‑by‑case basis, but “it would certainly raise some red flags” if a church directory were provided to a political campaign.
Churches and other faith groups may sell their membership rolls to campaigns if they are made available to all candidates and priced at “fair market value.”
The Bush‑Cheney campaign’s effort to acquire churches’ membership directories has come under fire from Democrats and church‑state watchdog groups.
The campaign recently sent instructions to volunteers titled “Coalition Coordinator Duties,” listing 22 tasks to be carried out by specific dates. The first is “Send your Church Directory to your State Bush‑Cheney ’04 Headquarters.” A copy of the instructions was obtained by Religion News Service.
The campaign workers’ other duties included identifying “another conservative church” to help organize “for Bush,” holding voter registration drives and hosting “a coffee/pot luck dinner/‘Party for the President’ with church members” on July 15.
A campaign spokesperson said the campaign had not asked churches for mailing lists, but has asked individuals about providing church directories.
The spokesperson, who asked not to be identified, said the campaign is not paying for the directories because they are “readily available, public information.”
IRS officials said that, if an individual turns in a church directory, and church officials “find out and they don’t do anything about it,” the church group would be in violation of IRS rules. It would not lose its tax‑exempt status unless it provided the registries “repeatedly,” one official said, but the first offense would probably bring a fine from the IRS.
Federal Election Commission guidelines forbid “membership organizations” from donating anything “of value” to political campaigns unless they first register as a political action committee, according to FEC spokesman Ian Stirton, who said a mailing list “could certainly be considered something of value.
Stirton said a church could qualify as a “membership organization.”
According to officials of several direct‑marketing firms, the value of a mailing list varies with the number of names and how “tailored” the names are to a buyer’s interest.
Jason Allely, an account executive for InfoUSA, a marketing firm that specializes in mailing lists and “sales leads,” said buyers pay from 12 to 18 cents per name.
Another executive said buyers typically pay $80 to $100 for every 1,000 names.
The Bush-Cheney campaign spokesperson said, “I am confident we are following the law.”
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