Subject: Comment on File Number 4-637

January 13, 2013

Securities and Exchange Comm.

Dear Securities and Exchange Comm.,

I strongly urge the Internal Revenue Service to launch an immediate investigation into the activities of the American Legislative Exchange Council (ALEC), and whether its tax-exempt status as a public charity should be revoked.

ALEC appears to be a platform whereby private commercial interests pay substantial sums of money to put their legislative interests in front of state legislators who can promote appropriate legislation. It develops and promotes model bills in task forces where only private business interests and legislators participate; there seems to be no attempt to review considerations of public benefit or social good. The driving force is promotion of corporate business interests. This would be all well and good for a chamber of commerce, but it is not charitable.

Yet by claiming to be a charity and calling participating legislators “members” ALEC attempts to evade disclosure of its lobbying, allows corporate members to deduct their payments as charitable contributions rather than non-deductible lobbying expenses, and does an end-run around state ethics laws intended to restrict the ability of businesses to buy access to legislators in order to promote their policy agendas. The IRS should stop allowing the continuation of this farce.


Mark Orlando