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March 3, 2014

Downsize DC’s Comment on IRS Regulation of c4 Groups

Electronically Submitted

(IRS REG-134417-13)

Federal Register: 2013-28492, Inc

872 Mark Dr.

Akron, OH 44313

February 27, 2014

Comment by, Inc. on the Notice of Proposed Rulemaking relating to

“Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities”

To Whom It May Concern:, Inc. is a 501(c)(4) organization that would be affected by this ruling, despite the fact that it has not run ads mentioning the name of an immediate candidate since the Citizens United Ruling. This is because we reserve the right to criticize a candidate's position or voting record.

Most days, we help 26,000 people communicate with their representatives in Congress. We call our program, the “Educate the Powerful System.”

We believe that Jefferson was right…

All governments rest upon the consent of the governed.

This rule was to be especially true of our unique government.

The system of delegated powers, where the people are the owners of their government, rather than The State owning its citizens, requires that persons be able to express dissent, free of State-imposed burdens. When bureaucracies can handicap the rules of expression, expression is no longer free.

501(c)(4) organizations provide millions of Americans with a means to magnify their voice, so that they are heard. Any billionaire can be heard! But the proposed rule changes, should they be approved, would place red tape over the mouths of millions of Americans.

Since 1959, it has been the IRS standard that c4 organizations are to be “primarily” engaged in “social welfare” activities. Now, you're considering redefining primarily to mean “exclusively.”

Under the separation of powers doctrine, the IRS has no legislative powers. Therefore, it is wrong for this agency to, unilaterally, overturn decades of lawful precedent. The people's Congress has had ample time to determine if c4 organizations have been so “primarily” engaged, but hasn't chosen to act. Therefore, the IRS should not succumb to political pressures to do Congress' job for them. In fact… addresses this kind of over-reaching behavior in our Write the Laws Act.

But it's also important to consider the term “social welfare.” What does that mean?

From the conscientious perspective of most of's supporters, both the acts of The State, as well as the consequences of those acts have a profound effect on the social welfare of the people. All-too-often, it seems that The State harms people, hurts families, damages industries, and destroys communities. It even kills people. Therefore, to ignore The State's actions is to ignore social welfare.

Further, to comment or publish, on the activities of an incumbent, is not necessarily a sign that a person or entity is favored in a given election. is not only legally non-partisan, we are temperamentally ANTI-partisan. This organization has always focused on the issues, from a principled standpoint, considering the social harm that might stem from piece of legislation or bureaucratic action. This has been done with zero consideration of the effects it might have on the electoral prospects of parties or candidates. But, Inc. reserves the right to comment on candidates should we at some point choose to do so for reasons of social welfare.

Redefining the word primarily to mean exclusively would effect us, tremendously. It would harm our supporters, who help us make this service available for free to the public. It would, in sum, steal our First Amendment rights of free association — the ability to join together to educate the powerful.

For these reasons, we urge rejection of the proposed changes in “Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities.”

Respectfully Submitted,

Jim Babka

President, Inc.

P.S., Inc. is a member of the Free Speech Coalition, which also submitted comments on this issue.

Tracking#: 1jy-8aok-23nm

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