Abstract
As is well known, on May 10, 2013, at a session of the American Bar Association Tax Section meeting in Washington, DC, Lois Lerner, at the time the director of the Exempt Organization Division of the Internal Revenue Service, apologized for IRS mishandling of applications by Tea Party groups for exemption as social welfare groups under § 501(c)(4) of the Code. A few days later, the Department of the Treasury Inspector General released a report (TIGTA Report) concluding that the “IRS used inappropriate criteria that identified for review Tea Party and other organizations applying for tax-exempt status based upon their names or policy positions instead of indications of potential political campaign intervention
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