Under a new Notice of Proposed Rulemaking, Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities (NPRM), the
The letter to OMB was signed for Judicial Watch by attorney
Specifically, the Judicial Watch letter to OMB cites the following "flaws" in the
•First ... the Service [
•Second, 'burden' is broadly defined in the PRA to include all of the 'time, effort, or financial resources expended by persons to generate, maintain, or provide information to or for a Federal agency,' including any time or other expenditure needed to review instructions, acquire technology, or search data sources ... Yet, the Service has completely ignored these components of burden.
•Third, the new inclusion of volunteer hours imposed an additional layer of recordkeeping and burden upon these non-profit organizations, many of which rely heavily upon local volunteers ... Anyone who has worked with volunteers knows that recordkeeping can be notoriously difficult -- how many volunteers are going to want to fill out time cards for their service? How many volunteers are going to be turned off from civic engagement due to this paperwork burden?
"In short," the Judicial Watch letter concludes, "the Service has failed to address the collection of information arising out of the NPRM's new term ... Consequently, the Service has not reviewed and evaluated the substantial burden this new term will place on nearly all of the 100,000 501(c)(4) organizations ... [W]e respectfully request that the Director disapprove of the collection of information contained in the NPRM ...." Because Judicial Watch does not engage in political activity, the NPRM does not directly affect the organization.
Source: Judicial Watch
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