/ . . . V FEDERAL ELECTION COMMISSION RECE^'^"' 

ZCiEFBJ? r::2:i9 

In the mattorof: ; 7 5'^ ..(. 

"" QFFICc^;- -i . 

American Conservative Union (.•"[>.' MUR No. 

Now or Never PAG / QO ^ 

James C. Thomas ill, Treasurer, Now or Never PAG ^ 

Unknown Respondent 

COMFLAINT SENSITIVE. 

1. Citizens for Responsibility and Ethics in Washington ("GREW") and Anne L. 

Weismann bring this corhplaint before the Federal Election Commission ("EEC") seeking an 

immediate investigation and enforcement action against the American Conservative Union, Now 

or Never PAG, James G. Thomas III, and an Unknown Re.spondent for direct and serious 

violations of the Federal Election Campaign Act ("FEGA"'). 

Complainants 

2. Complainant CREW is a non-profit corporation, organized under section 

501(c)(3) of the Internal Revenue Code. CREW is committed to protecting the right of citizens 

to be informed about the activities of government officials and to ensuring the integrity of 

government officials. CREW seeks to empower citizens to have an influential voice in 

government decisions and in the governmental decision-making process. CREW uses a 

combination of research, litigation, and advocacy to advance its mission. 

3. In furtherance of its mission, CREW seeks to expose unethical and illegal conduct 

of those involved in government. One way CREW does this is by educating citizens regarding 

the integrity of the electoral process and our system of government. Toward this end, CREW 

monitors the campaign finance activities of those who run for federal office and those who make 

expenditures to influence federal elections, and publicizes those who violate federal campaign 

finance laws through its website, press releases, arid other methods of distribution. CREW also 
files complaints with the FEC when it discovers violations of the FECA. Publicizing campaign 

finance violations and filing complaints with the l-'EC serve CREW's mission of keeping the 

public informed about individuals and entities that violate campaign finance laws and deterring 

future violations of campaign finance law. 

4. Complainant Anne L. Weismann is the interim executive director and chief 

coun.sel of Citizens for Responsibility and Ethics in Washington, a citizen of the United States, 

and a registered voter and resident of Maryland. Both as a voter and as part of her 

responsibilities for CREW, Ms. Weismann is committed to ensuring the integrity of federal 

elections and the campaign finance requirements of the FECA. To that end, Ms. Weismann 

reviews campaign finance filings and media reports to determine whether candidates and 

4 political committees comply with the requirements of the FECA. 

5. When CREW and Ms. Weismann discover a violation of the FECA, they submit 

complaints again.st violators pursuant to their rights under the FECA. 52 U.S.C. § 30109(a)(1). 

CREW and Ms. Weismann rely on the FEC to comply with the FECA when making its 

enforcement decisions because the FEC is the exclusive civil enforcement authority for 

violations of the FECA. 52 U.S.C. §-30107(e). CREW and Ms. Weismann are injured if the 

FEC dismisses their complaints contrary to the FECA. 

6. In addition, in order to assess whether an individual, candidate, political 

committee, or other regulated entity is complying with federal campaign finance law, CREW 

needs the information contained in receipts and disbursements disclosure reports political 

committees must file pursuant to the FECA, 52 U.S.C. § 30104(a); 11 C.F.R. § 104.1. CREW is 

hindered in its programmatic activity when an individual, candidate, political committee, or other 

regulated entity fails to disclose campaign finance information in reports required by the FECA. 
7. CREW relies on the EEC's proper adminisiration of ihe EECA's reporting 

requirements because the FtXA-mancialcd disclosure reports are the only source of information 

CREW can use to determine if an individual or entity is complying with the FECA. The proper 

administration of the EECA's reporting requirements includes mandating that all disclosure 

reports required by the FECA are properly and timely filed with the FEC. CREW is hindered in 

its programmatic activity when the EEC fails to properly administer the EECA's reporting 

requirements, because it denies CREW information to which it is statutorily entitled. 

8. Ms. Weismann also is entitled to receive information contained in di.sclosure 

reports required by the FECA, 52 U.S.C. § 30104(a); 11 C.F.R. § 104.1. Ms. Weismann is 

harmed when an individual, candidate, political committee or other entity fails to report 

g campaign finance activiiy as required by the FECA. .Str FEC v. Akins, 524 U.iS. 11, 19 (1998), 

quoiing Buckley v. Valeo, 424 U.S. V, (S6-67 (1976) (political committees must disclose 

contributors and disbursements to help voters understand who provides which candidates with 

financial support). Ms. Weismann is further harmed when the ETEC fails to properly administer 

the FECA's reporting requirements, limiting her ability lo review campaign finance information. 

Respondents 

9. The American Conservative Union ("ACIJ") is a tax-exempt organisation formed 

in 1964 and organized under section 501(c)(4) of the Internal Revenue Code.' 

10. Now or Never PAC is an independent-expenditure only committee ("super PAG") 

formed in 2012.^ 

11. Mr. Thomas is the irea.surer of Now or Never PAC."^ 

' ACU 2012 Inilial Korin 990, November 14, 2013. al t (excerpts altadtciJ as Exhibit A). 

- Now ot Never PAC, FEC I'orrn 1, Stalemciit of Organization. I'ebruary 21, 2012, available at 

3074449h.ndl'. 
12. Unknown Respondent is the true .source of funds ACU transferred to Now or 

Never PAC. 

Factual allegations 

13. During the 2012 election cycle. Now or Never PAC's reported spending 

$7,760; 174 on independent expenditures." 

14. Now or Never PAC disclosed receiving $8,200,500 in contributions during the 

2012 election cycle." The largest contribution the group disclosed to the PEG was from ACU, 

which Now or Never PAC said contributed $1,710,000 on October 31, 2012.'^ Mr. Thomas 

electronically signed the form, certifying he had examined the report and it was true, correct, and 

complete to the best of his knowledge and belief.^ 

15. ACU initially filed its 2012 Internal Revenue Service ("IRS") Form 990 tax return 

in November 2013.® Despite Now or Never PAC's report to the FEC of receiving the $1.71 

million contribution, ACU asserted to the IRS it did not engage in any direct or indirect political 

campaign activities, and did not disclose making any contribution to Now or Never PAC.' 

16. In April 2014, ACU's tax preparer provided the organization the results of its 

independent auditor's report of ACU's finanees for 2012.'" Contrary to ACU's initial tax return, 

the auditor's report asserted ACU made a $1.71 million political donation in 2012." 

' Now or Never PAC, Two-Year Summary for 2012, available at hiip.7/fm-.uov/rinaiiLC/disclo.'iurc:'ciindcmle 

info-shlml. 

' Now or Never PAC, FEC Form 3X. 2012 Post-Election Rcoori. December .S, 2012, available at 

liii|i:.'/d(icquerv.rcc.ijov/pdt/%8/:l29fl2832%S/12%2S;v2<lbS.ndf#navp:incs=fl. 

'W. 

ACU 2012 Initial Form 990, at 1. 

'' Id., Pan IV, Question 3. 

Conlon and Associates, American Conservative Union. Finaneial Statements and Independent Auditor's Report 

for the Year Ended December 31. 2012. April 9, 2014 (attached as Exhibit B). 

" Id. at 6. 
I 

17. A monlh hilcr, in M:iy 2014, ACU filed an amended 2012 lax relurn with ihc 

IRS.'- This tax relurn acknowledged ACU engaged in political campaign acliviiies in 2012, and 

furlhcr disclosed ACU's SI.71 million eoniribulion lo Now or Never PAC.'' The funds for this 

contribution, however, were not from ACU. According lo ACU's amended lax return, ACU 

acted as a eonduil for a contribution earmarked to Now or Never PAC.''' 

18. IRS regulations permit tax-exempt organizations to accept political contributions 

and "promptly and directly" transfer those funds to a separate, segregated fund. 26 C.P.R. § 

1.527-6(c). The IRS instructions for reporting political contributions characterize such transfers 

^ as occurring when a "section 501(c) organization collects political contributions or member dues 

earmarked for a separate segregated fund, and promptly and directly transfers them lo that 

fiind."'"^ 

19. ACU's tax return designates its contribution to Now or Never PAC as this type of 

transfer. As ACU explained, the "$1,710,000 was a political contribution received by the 

Organization and promptly and directly delivered to a separate political organization.""' 

Confirming the designation, in reporting the transfer, ACU filled out "0" in the column for the 

"[a]mount paid from filing organization's funds,'" and put "1,710,000" in the column for 

"la]mount of political contributions received and promptly and directly delivered to a separate 

political organization."'^ 

" ACU 2012 Amended Form 990, May 12, 2014 (cxccrpis aiiaclicd as Exliiliit C). 

" /f/.. Pan lY, Question 3 and Sclicdulc C, Part I-C, Line 5. 

" /{I., Scliedulc C, Pan I-C, I..inc 5(d), (e) and Sclicdulc O. 

IRS, 2014 Insiructions for Schedule C (Form 990 or 990-E2'>, al 3, awUahli: at iiii[i://ww\\'.irs.i:iu.'pLiivir.sACU 2012 Amended Form 990, Schedule O. 

" W.. Schedule C, Pan I-C, Line 5 (d), (c). 
20. Even though ACU was not the source of the transferred funds, Now or Never 

PAC reported ACU as the contributor.'" ACU has not publicly identified the contributor who 

provided the $1.71 iniilion contribution it delivered to Now or Never PAC. 

Count I 

21. The FECA and FEC regulations prohibit knowingly permitting one's name to be 

u.sed to effect a contribution in the name of another person and knowingly helping or assisting 

any person in making a contribution in the name of another. 52 U.S.C. § 30122; 11 C.F.R. § 

110.4(b). 

22. ACU admitted in its amended 2012 tax return - filed under penalty of perjury -

that it received a $1.71 million political contribution earmarked for Now or Never PAC, then . 

promptly and directly delivered the contribution to the super PAC. ACU further reported that 

none of the money transferred to Now or Never PAC came from ACU's funds. As a result, ACU 

knowingly permitted its name to be used to effect the contribution and knowingly helped the 

undisclosed donor make the contribution, in violation of 52 U.S.C. § 30122 and 11 C.F.R. § 

110.4(b). 

23. Any person who knowingly and willingly violates any provision of the FECA 

involving the making, receiving, or reporting of any contribution aggregating more than $25,000 

in a calendar year is subject to up to five years in prison and fines. 52 U.S.C. § 30109(d)(1). 

ACU only disclosed the contribution to Now or Never PAC after an independent audit of its 

2012 finances, and its amended 2012 tax return reported ACU simply acted as a conduit for a 

contribution by an undisclosed donor. As a result, ACU's conduct was knowing and willful, and 

Now or Never PAC, FEC Form 3X. 2012 Post-Election Report. December 5, 2012, avuitable at 

luio:.//Uocuuerv.rec.e..v/iuir/968,-.129ft2H.12%8/12%2S.32968.nd|-. 
thus subject to criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 

30l()9(a)(5)(C), (d)(1). 

Count II 

24. The FECA and PEG regulations also prohibit knowingly accepting a contribution 

made by one person in the name of another. 52 U.S.C. § 30122; 11 C.F.R. § I l().4(b). 

25. If Now or Never PAC knowingly accepted a $1.71 million contribution from 

ACU made in the name of another. Now or Never PAC violated 52 U.S.C. § 30122 and 11 

C.F.R. § 110.4(b). If Now or Never PAC's violations were knowing and willful, they also are 

subject to criminal penalties and referral to the Department of Justice. 52 U.S.C. §§ 

30109(a)(5)(C), (d)(1). 

Count 111 

26. The FECA and FEC regulations further prohibit making a contribution in the 

name of another person. 52 U.S.C. § 30122; 11 C.F.R. § 110.4(b). 

27. The Unknown Respondent provided to ACU the $1.71 million it iii turn 

transferred to Now or Never PAC. By making a contribution to Now or Never PAC in the name 

of ACU, the Unknown Respondent violated 52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b). If the 

Unknown Respondent's violations were knowing and willful, they also are subject to criminal 

penalties and referral to the Department of Justice. 52 U.S.C. §§ 30109(a)(5)(C), (d)(1). 

Conclusion 

WHEREFORE, Citizens for Responsibility and Ethics in Washington and Anne L. 

Weismann request that the FEC conduct an investigation into these allegations, declare the 

respondents to have violated the FECA and applicable FEC regulations, impo.se .sanctions 
appropriaie lo ihesc violalions ancl lake such furlher action as may be appropriate, including 

referring this case to the Department, of Justice for criminal prosecution. 

ON BEHALF OF COMPLAINANTS 

Anne L. Wcismann 

Interim Executive Director 

Citizens for Responsibility and Ethics in 

Washington 

455 Massachu.setts Ave.. NW. Sixth Floor 

Washington, D.C. 20001 

(202) 408-5565 (phone) 

(202) 588-5020 (fax) 
Verificiilion 

Citizens fur Responsibility.and Ethics in Washington and Anne L. Weismann hereby 

verify that the statements made in the attached Complaint arc, upon information and belief, true. 

Sworn pursuant to 18 U.S.C. § 1001. 

Anne L. Weismann 

Sworn to and subscribed before rne this:37th day of February, 2014. 

Notary Public 

11^ li 

*0 
EXHIBIT A 
c« 

Fam 990 

D«pann>enl of the 7r<uwnr 

Inlirruj Rovenuo Scive* 

Return of Organization Exempt From Income Tax 

Under section 501(c), 527, or 4947(a)(1) of the Internal Revenue Code (except black lung 

benefit trust or private foundettlon) 

^ The organization may have to use a copy of this return to satisfy state reporting feouirements. 

0MB No I5>5-W»' 

^@12. 

Open to Public 

Inspection 

8 Check if appiiealilo' 

Q Address Change 

O Name Change 

O Initial return 

• Tonninaied 

D Amended return 

Q Apolieatian pending 

C Name ol organiiaiion Amcncan Conservative Union. Inc. 

Dang Busmeas As 52-0810813 

Numbei a.hd atreei (or P 0 bos il mail la not daiivsied to street address) 

1331 H Street NW 

BoonVsuns 

500 

E Talsphone number 

202-347.9388 

City, town Of pest office, state, and ZIP coda 

Washington. DC 20005 j a Gross reeapts 6 6^478,581 

F Name and address olonncipalolheef Al Cardenas. Chairman 

1331 H SUcet NW, Washington, [3C 20005 

I Tax eaemel status • 5QHC1I3I BsOtlcll 4 )< (insert no) • <9471sl(llor • S2? 

J tWebeWe: • conscrvative-cro 

K Form Ql eigengaipn E Corporation • Tnrst 

SumiTtary 

H|o)fcltaigrajeiciumlaii»itnlUYos l^No 

H(b)Aioell affiliates includad? Dves ONO 

II 'No.* BtlBCh a list tsae instructions} 

M(c) Group evempiBn nuwtror • 

Olhore L voarolfotmabon 1964 I M Sialo ol legsl domole PC 

OO 

I=!i 

t-J 

UJ 

o 

CS 

s 

25; 

Brietly describe the orgsftization's fnission or most signHicant activllies; The miss^ton of the 

}?..S!l'?.l?.S??H.5?A®J.bepyMe.??.?Jfl.5VTOriA9J-leU?J5?JP.ffi5j.ep.4KJlV,5?!.'.55}ifi.%-_ 

2 

3 

4 

5 

6 

7a 

b 

Check this box ^ • H the organization discontinued its operations or disposed of more than 2556 of its net assets. 

Number of voting mernbers ol the governing body (Part Vi, line 1a) 

Number of independent voting memt>ers of the governing body (Part VI, line 1 b) 

Total number of individuals employed in calendar year 2012 (Part V. bne 2a) 

Total number of volunteers (estimate If necessary) 

Total unrelated business revenue from Part Viil, column (C), line 12 .... 

Net unrelated business taxable income >iom Form 990-T, line 34 ... , 

8 Confnbufions and grants (Part Viil, lino 

9 Program service revenue (Part VIII, line 

10 Investment income (Pari VIII, column (A 

11 Other revenue (Part VIII, column (A), lini 

12 Total revenue—add lines B through 11 

13 

14 

15 

IGa 

b 

17 

18 

19 

:g)' §??6CE8VEDl-. and 7d) • 

,iS.Co8n4.iu 

artjj 

i; lines 1-3)-S-JQ: 

'"^4), UT • 

'afn)crcotomtr(A)i.-|if» 

, colun 

Grants and similar amounts paid (Part 

Benefits paid to or for members (Part I 

Salaries, other compensation, employee 

Professional fundraising tecs (Part IX. column (A). Bne 11e) 

Total fundraising expenses (Part IX, column (O), line 25) b' 

Other expenses (Part IX, column (A), lines 11 a-lld, 11 f-24e) . . . 

Total expenses. Add lines 13-17 (must equal Part IX,-column (A), line 25) 

Revenue less expenses. Subtract line 18 from line 12 

7a 

7b 

Fftor Voar 

3.941,967 

465.984 

525.064 

109,648 

246.673 

20 

21 

22 

Total assels (Pan X, line 16) 

Total liabilities (Part X. line 26) 

Net assels or tund balances. Subtract line 2i from line 20 

Signature Block 

i 

32 

32 

11 

100 

Currant Year 

361,205 

5.860,620 

.236JS6 

6.478.S8I 

891.539 

171.456 

3.704.685 

4,339,397 

433,157 

eagkinng at Cumf Yur 

1.682,689 

1.104.178 

578.511 

_LZ15.Z32 

EndetYmr 

jyieaei 

JGSJ91 

666,526 

J98J65 

Unan panailm of poivy. • doclore Uiat I r 1 this ratum. VKtudmg accompanying achaCuias and atalamenu, and lo IXs ben of my kno 

erua. ootraci. and compMe OoctoraMfn of preparer (other ihon officci) ii tusod on tU mformaiian of wfucn preparer tias any knoadodge 

I and betief. It a 

Sign, 

Here 

T 

Paid 

Preparer 

Use Only 

r Sig.-uture of officer Oato 

r Type or pnnt name and tiffs 

Pnnt/Tyee pieoarcf's name 

Thomas R. Conton CPA 

Prepartt'a signature Date Cheek Q it 

seit-emptoyad 

PUN 

P01486002 

fmn't noma • Conlon t Associates. LLC Finn's EIN • 

Finn i adorosa • PO Box 6213. Silver SPfinq, WD 20916-6213 and 301-598-6aSt 

May the IRS discuss this retum with the (yeparer shown above? (see instructions) • Yes • Wo 

For Paperwork Reduction Act Notice, see die separate Instructions. Cat No fl2S2V Fonn 990^1 h 
B 

Form 990 (1012) 52-0810813 Psga2 

1^301 statement of Program Service Aceomptishments ^ 

Check if Schedule O contains a response to any question in this Part III • 

1 Briefly descnbe the organization's mission: 

2 Did the organization undertake any significant program services during the year which were not listed on the 

prior Form 990 or 990-EZ? QVes 0No 

If "Yes," describe these new services on Schedule O. 

3 Did the organization cease conducting, or make significant changes in how it conducts, any program 

services? DYes 0No 

If "Yes," describe these changes on Schedule O. . 

4 Describe the organization's program sen/ice accomplishments for each of its three largest program services, as measured by 

expenses. Section SOI (c)(3) and 501 (c)(4) organizations are required to report the amount of grants and allocations to others, 

the total expenses, and revenue, if any, for each program service reported. 

4a (Code: )(Expenses $ s.344,t90 including grants of S ) (Revenues ) 

ItffiJ9.'5?.9!?AlL9P.F.9.niWy.9!HlS!tl®j'.n^l.?.99.?Rf.99..fh?.puWicah9UlFu.PSnt_soci8j, economic^ 

P9.PXPA!P.'fiC9??AJ.9P.!hr9>rahoia_lJta^ear The OrjganiuUqn conduMGd rn^ 

jPJl!yi9.9aJp.an9.99[R9.'aAlonsjregar(ling£pjjUcaJ.is$uesan(l igeduutejeder^ 

ontbejieed w_address 

4b (Code: ) (Expenses S including grants of S ) (Revenue S 

4c (Code: ) (Expenses $ including grants of $ ) (Revenues ) 

4d Other program services (Describe in Schedule O.) 

(Expenses S including grants of S ) (Revenue $ ) 

4e Total program service expenses ^ ts.344.iso 

Form 990 poii) 
Form 090 (2012) b2-0ylU813 

Checklist of Pcquired Schedules 

Page 3 

Part IV 

.4 

10 

11 

e 

f 

12 a 

13 

14 a 

b 

15 

16 

17 

18 

19 

20a 

b 

Is (he organization described in section S01(c)(3) or 4947(a)(1) (other than a private foundation)? II "Yes,* 

compietB Schedule A 

Is the organization required to complete Schedule 8, Schedule of Contfibulors (see instructions)? . . . 

Did the organization engage in direct or indirect political campaign activities on behalf of or in opposition to 

candidates for public office? H 'Yes,'complete Schedule C. Part I ... 

Section 501(c)(3) organizations. Did the organization engage In lobbying activities, or have a section 501(h) 

election in effect dunng the tax year? If 'Yes." complete Schedule C. Part II 

Is the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization that receives membership dues, 

assessments, or similar amounts as defined in Revenue Procedure 98-19? If "Yes." complete Schedule C, 

Part III 

Did the organization maintain any donor advised funds of any similar funds or accounts for which donors 

have the right to provide advice on the distribution or investment of amounts in such funds or accounts? If 

"Yes," complete Schedule D, Part I 

Did the organization receive or hold a conservation easement. Including easements to preserve open space, 

the environment, historic land areas, or histonc stnictures? If "Yes," complete Schedule 0, Part «... 

Did the organization maintain coliections of works of art, historical treasures, or other similar assets? If 'Yes," 

complete Schedule D, Part III 

Did the organization report an amount in Part X, line 21, lor escrow or custodial account liability; serve as a 

custodian for amounts not listed in Part X; or provide credit counseling, debt management, credit repair, or 

debt negotiation services? If "Yes." complete Schedule D, Part IV 

Did the organization, directly or through a related organization, hold assets in temporarily restricted 

endowments, permanoni endowments, or quasi-endowments? II "Yes," complete Schedule O, Part V . . 

If the organization's answer to any ol the ((Xiowing questions is "Yes." then complete Schedule D, Parts Vt, 

VII, yill, IX, orX as applicable. 

Did the organization report an amount for land, buildings, and equipment In Part X, line 10? If "Yes." 

complete Schedule O. Part Vl 

Did the organization report an amount for Investments—other securities In Part X, line 12 that is 515 or more 

of Its total assets reported in Part X, line 16? If "Yes," complete Schedule D, Part VII 

Did the organization report an amount lor Investments—program related In Part X, line 13 tfiat is 5% or more 

Of its total assets reported in Pari X. line 16? II "Yes." complete Schedule 0. Part VIII 

Did the organization report an amount lor other assets In Part X. line 15 that is 5% or more of its total assets 

reported In Part X. line 167 If 'Yes.'complete Schedule D. Part IX 

Did the organization report an amount tor other liabilities in Part X. line 25? If 'Yes.' complete Schedule 0. Part X 

Did the organization's separate or consolidated financial statiements for the tax year Include a footnote that addresses 

the organization's iiability for uncertain tax positions under FIN 48 (ASC 740)? II "Yes,' complete Schedule 0. Part X . 

Old the organization obtain separate, independent audited financial statements for the tax year? If "Yes,' complete 

Schedule D. Parts XI and XII 

Was the organization included in consolidated, independent audited financial statements for the tax year? If 'Yes,' and if 

the organization answered 'No' to line 12a, then completing Schedule D, Parts XI andXII is optional 

Is the organization a school described in section 170(b)(1 XAXIi)? " "^es. * complete Schedule E ... . 

Did the organization maintain an office, employees, or agents outside of the United States? 

Did the organization fiave aggregate revenues or expenses of more than S10.000 from grantmaklng, 

fundraising, business. Investment, and program service activities outside the United States, or aggregate 

foreign investments valued at $100,000 or more? If "Yes," complete Schedule F, Parts I and IV 

Did the organization report on Part iX. column (A), line 3, more than SS.OOO of grants or assistance to any 

organization or entity located outside the United States? If "Yes, * complete Schedule F, Parts II and IV . . 

Did the organizatiori report on Part IX, column (A), line 3. more than $5,000 of aggregate grants or assistance 

to individuals located outside the United States? If "Yes, * complete SchediXe F, Parts III and IV ... . 

Did the organization report a total of more than $15,000 of expenses for professional fundraising services on 

Part IX, column (A), lines 6 and 11e? It "Yes." complete Schedule G. Part I free insfructionsj 

Did the organization report more than $15,000 total of fundraising event gross income and contributions on 

Part Vlii. lines 1 c and 8a? If "Yes," complete Schedule G. Part II 

Did the organization report more than $15,000 of gross income from gaming activities on Part Vlli, line 9a? 

If 'Yes.' complete Schedule G. Part III 

Did the organization operate one or more hospital facilities? If "Yes." complete Schedule H 

if "Yes" to iine 20a, did the organization attach a copy of its audited financial statements to this return? 

Voa No 

1 • 

2 / 

3 • 

4 

5 • 

8 / 

7 • 

8 / 

9 / 

10 / 

lie • 

lib / 

11c / 

lid / 

lie / 

111 / 

12a / 

12b / 

13 / 

14a / 

14b / 

15 / 

16 / 

17 / 

18 / 

19 / 

20a / 

20b 

Fonii990BO12| 
4 

EXHIBIT B 
AMERICAN CONSERVATIVE UNION, INC. 

Financial Statements 

And 

independent Auditor's Report. 

For The Year Ended December 31, 2012 

Conlon and Associates 

Certiried Public Accountants 
7 / • 

1 

1 

/ 

0 CONTENTS 

1 

4 

PAGE 

rNDEPENDENT AUDITOR'S REPORT 2 

Statement of Financial Position, as of December 31, 2012 3 

Statement of Activities, Year Ended December 31, 2012 4 

Statement of Cash Flows, Year Ended December 31, 2012 5 

Statement of Functional Expenses, Year Ended December 31, 2012 6 

Notes to Financial Statements 2-10 
'I / • 

I 

1 • •-

/ 

2 

» CONLON AND ASSOCIATES 

I CER-nnEDPUBUC ACCOUNTANTS 

INDEPENDENT AUDITOR'S REPORT 

The Board of Directors 

American Conservative Union, Inc. 

Washington, D.C. 

We have audited ihc accompanying finarKial sutemenis of the American Conservative Union, 

Inc. (Organiaation), which comprise the statement of financial position as of December 31, 20)2, and the 

related statements of activities, cash flows, and funciionaf expenses for the year then ended, and the 

related notes to the financial statements. 

^ Management's Responsibility for the Fioancial Statements 

P Management is responsible for the preparation and fair presentation of these financial statements 

^ in accordance with U.S. generally accepted accounting principles; this includes the design, 

^ implemenution, and maintenance of internal control relevant to the preparation and fair presentation of 

A financial statements that are frte from material misstatement, whether due to fraud or error. 

^ Auditor's Respoosibiiiiy 

Our responsibility is to e.xpress an opinion on these financial sutemenu based on our audit. We 

conducted our audit in accordance with U.S. generally accepted auditing standards. Those standards 

require that we plan and perform the audit to obtain reasoriabic assurance about whether the financial 

siatemenis are fVee from material misstatement. 

An audit involves performing procedures to obtain audit evidence about the amounts and 

disclosures in the financial statements. The procedures selected depend on the auditor's judgment, 

including the assessment of the risks of material misstatement of the financial statements, whether due to 

fraud or error, in making those risk assessments, the auditor considers internal control relevant to the 

entity's preparation and fair presentation of the financial statements in order to design audit procedures 

that are appropriate in the circumstances, but not for the purpose of e.xpressing an opinion on the 

effectiveness of the entity's internal control. Accordingly, we express no such opinion. An audit also 

includes evaluating the appropriateness of accounting policies used and the reasonableness of signiricani 

accounting estimates made by management, as well as evaluating the overall presentation of the financial 

statements. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a 

basis for our audit opinion. 

OpioioD 

In our opinion, the financial statements referred to above present fairly, in all material respects, 

the financial position of the American Conservative Union, Inc. as of December 31; 2012, and the results 

if its operations and its cash flows for the year then ended, in accordance with U.S. generally accepted 

accounting principles. 

April 9, 2014 

SILVER SPRING, MD • TELEPHONE- (301) 596-6851 • FACS1MII£: (301) 598-3736 

' Email: fpnloncp»ffm5n.com 
AMERJCAJV C0NSERVATI\'E UNION, INC. 

Statemeal of Financial Position 

As of December 31,2012 

4 

4 

ASSETS 

Cash and cash equivalents 

Prepaid expenses 

Property and equipment (net of accumulated depreciation of 584,370). 

Rent deposit 

Other assets 

TOTAL ASSETS 

LIABILITIES 

Accounts payable 

Due to American Conservative Union Foundation, Inc. 

Revenue received in advance 

Other liabilities 

TOTAL LIABILITIES 

NET ASSETS 

Unrestricted 

Total net assets 

TOTAL LUBILITIES ArND NET ASSETS 

S 479.682 

491,218 

135,686 

26,396 

1-155.307 

41.879 

140.468 

594,216 

217.186 

993.749 

161,558 

161.558 

S 1.155.307 

The Notes to the Financial Statements are an Integral Part of These Statements 

3 
AMERICAN CONSERVATIVE UNION, INC. 

Staiement of Activities 

For the Year Ended December 31, 2012 

REVENUES AND OTHER SUPPORT 

Contributions 

Conference fees 

Member dues and serv ices 

Management fees 

Other revenue 

TOTAL REVENUES AND OTHER SUPPORT 

EXPENSES 

Program 

Management and general 

Fundraising 

TOTAL EXPENSES 

CHANGE IN NET ASSETS 

NET ASSETS AT BEGINNING OF YEAR 

.VET ASSETS AT END OF YEAR 

8,413,603 

1,589,378 

71,900 

164,828 

37,414 

10,277,123 

8,612,669 

722,202 

1,359,205 

10,694,076 

(416,953) 

578,511 

161,558 

The Noies to the Financial Suiemenis are an Integral Part ofThese Statements 

4 
AJMERICAN CONSERVATIVE UiNiON, INC. 

Statement of Cash Flows 

For the Year Ended December 31, 2012 

CASH FLOWS FROM OPERATING ACTIVITCES 

.4 

Change in net assets S (416.933) 

Adjustments to reconcile change in net 

assets to cash provided by operating activities: 

Depreciation 33,978 

(increase) decrease in operating assets: 

Funds in escrow- 409,529 

Prepaid e.xpenses (252,366) 

Increase (decrease) in operating liabilities: 

Accounts payable and accrued expenses (46.359) 

Due to .American Conservative Union Foundation 104,994 

Revenue received in advance (350,092) 

Other liabilities 181.028 

Net Cash Used by Operating Activities (336,241) 

CASH FLOWS FROM INNTSTING ACTmXIES 

Payments for property and equipment (147,300) 

Net Cash Used by Investing Activities (147,300) 

NET CH.ANGE LN CASH (483,541) 

CASH AND CASH EQUIVALE.NTS AT BEGINNING OF YEAR 963,223 

CASH AND CASH EQUIVALENTS AT END OF YEAR $ 479.682 

The Notes to the Financial Statements are an Integral Part of These Statements 

5 
AMERICAN CONSERVATIVE UNION, INC. 

Statemeni of Functional E.xpenses 

For the Year Ended December 3 i, 2012 

4 

Management 

Expense Category Program And General Fundraising Total 

Advertising $ 30,000 S 19,423 S S 49,423 

Benefits, employee 61.026 7,203 12,707 80,936 

Compensation, employee 594,653 70,367 124,167 789.187 

Consultants, accounting - 13,354 13,334 

Consultants, liirect mail 3,366,483 - 1,005,373 4,372,056 

Consultants, professional fundraising - . - 124,872 124,872 

Consultants, legal - 103,881 103,881 

Consultants, lobbying 54.600 • 54,600 

Consultants, other 179,831 3,850 27,583 211,264 

Depreciation - 33,978 33,978 

Information technology 4,304 46,035 . 50,339 

Insurance - 11,380 11,380 

Interest - 2,104 2,104 

Meetings and conferences 2,261,347 279.600 2,540,947 

Occupancy 116,832 13,791 24,327 154,950 

Office 41,605 92,374 133,979 

Political donations 1,710,000 - 1,710,000 

Taxes, payroll 40,522 4,783 8,438 53,743 

Travel 151,466 17,879 31,338 200,883 

Total S 8.612.669 S 722,202 S 1,359.205 S 10,694.076 

The Notes to the Financial Statements are ah Integral Pan of these Statements 

6 
I 

AMERICAN CONSERVATIVE UNION, INC. 

4 Notes To Financial Statements 

As of and for the Year Ended December 31,2012 

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

Organization 

The American Conservative Union (Organization) was incorporated as a non-stock, nonprofit 

corporation in the Commonweaiih of Virginia in 1964. In 2006, the Organization incorporated in 

the District of Columbia, under the District of Columbia Nonprofit Corporation Act. 

The mission of the Organization is to educate the public about current social, economic, and 

political issues. 

4 Significant accounting policies are as follows: 

4 

4 Basis of Presentation i 

I 

Financid statement presentation follows the recommendations of the FASB .ASC 958-205 

Presemhiion of Financial Statements for Notfor-Profit Organisations. Under FASB ASC 958-

205, the Organization is required to report infonmation regarding its financial position and 

activities according to three classes of net assets: unrestricted net assets, ictnporarily restricted 

net assets, and permanently restricted net assets. The Organization did not have any temporarily 

or permanently restricted net assets.at December 31,2012. 

Use of Estimates 

The preparation of financial statements in conformity with accounting principles generally 

accepted in the United States of America requires managemetit to make estimates and 

assumptions that affect: (1) the reponed amounts of assets anti liabilities and disclosure of 

contingent assets and liabilities at the date of the financial sutements; and (2) the reported 

amounts of revenues and e.xpcnscs during the reporting period. Actual results could differ from 

those estimates. 

Income Ta.xes 

The Organization is e.tempt from federal income ta.xes under section 501(a) of the Internal 

Revenue Code, as an organization described in section 501(c)(4). 

The Organization's income ta.x returns are subject to review and e.xamination by federal and state 

authorities. The Organization is not aware of any activities that would jeopardize its tax-exempt 

status. The Organization is not aware of any activities that are subject to tax on uivelated 

business income. 
4 

AMERJCAN CONSERVATIVE UNION, INC. 

Notes To Financial Statements 

As of and for the Year Ended December 31, 2012 

NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES, CONTINUED 

Revenue Recognition 

Contributions are recognized when the donor makes a promise to give to the Organization that is, 

in substance, unconditional. Contributions are considered to be available for unrestricted use 

unless specifically restricted by the donor. Support that is resuicted by the donor is reponcd as 

an increase in temporarily restricted net assets, depending on the nature of the restriction and 

when the restrictions are met. When a restriction expires (that is, when a stipulated time 

restriction ends or the purpose of the restriction is accomplished), temporarily restricted net 

assets are reclassified to unrestricted net assets in the Statement of Activities. Revenue received 

with temporary restrictions that are met in the same reporting period is reported as unrestricted 

support, and increases unrestricted net assets. 

Other types of revenue, such as conference fees, memberships, and management fees are 

recognized when earned. 

Functional Classification of Expenses 

The Organization allocates its expenses on a functional basis among program, and management 

and general, and fundraising, according to their natural expenditure classification. 

Related Party Transactions 

The Organization is under common control with the .American Conser\'ative Union Foundation, 

Inc. (Foundation). The Foundation is organized e.xciusively for charitable, religious, education, 

and/or scientific purposes under Section 501(c)(3) of the Interaal Revenue Code. A majority of 

the total number of voting directors of the Foundation shall at all times be current or former 

voting members of the Board of Directors of the American Conserx'ative Union, inc. There is no 

financial interest bet\veen the Organization and the Foundation. However, the Organization 

received management fees of 5164,828 from the Foundation in 2012. 

Cash and Cash Equivalents 

The Organization considers all investments wth an original maturity of three months or less to 

be cash equivalents. 
AMERICAN CONSERVATIVE UNION, INC. 

Notes To Financial Statements 

As of and for the Year Ended December 31,2012 

NOTE 2: PROPERTY AND EQUIPMENT 

Cost incurred to purchase office equipment and furnishings are capitalized and depreciated over 

the estimated useful life, on a straight-line basis. 

NOTE 3: DUE TO AMERICAN CONSERVATIVE UNION FOUNDATION, INC. 

The Organization, at December 31, 2012 owed $140,468 to the America Conservative Union 

Foundation, a related party. 

NOTE 4: REVENUE RECEIVED IN ADVANCE 

A The revenue was received in advance for a conference held in 2013. 

4 

I NOTE 5: ADVERTISING COSTS 

3 The Organization incurs advertising costs in order to advocate for its mission. Advertising costs, 

.6 which totaled 549,423, are classified 530,000 as program costs. Other non-program related 

3 advenising costs of S19,423 are classified as management and general costs. All advertising 

costs are e.\penscd in the year incurred. 

NOTE 6. JOINT COSTS RELATING TO PROGRAM AND FUNDRAISING 

The Organization conducts direct mail campaigns that are partly a fundraising function and 

partly provide program education. The costs of 54,372,056 associated with direct mail 

processing, printing, and postage, arc allocated 53,366,483 to program and 51,005,573 to 

fundraising costs, based on the facts and circumst^ccs of each mailing. 
AMERICAN CONSERVATIVE ONION, INC. 

Notes To Financial Statements 

As of and for the Year Ended December 31,2012 

NOTE 7; OPERATING LEASE 

The Organization is party, as tenant, to a lease commencing December 15, 2011, for a period of 

five years. The estimated future lease payments for the next five years, which are based on an 

average annual increase of four percent per year, are as follows. Fifty percent of the first seven 

months of base rent shall be abated. 

Lease Year 

1 S 164,708 

2 171,297 

3 • 178,149 

4 185.275 

Aggregate S 699.429 

NOTE 8: SUBSEQUENT EVENTS 

In preparing these financial statements, the Organization has evaluated events and transactions 

for potential recognition or disclosure through April 9,2014, the date the financial statements 

were available to be issued. 

NOTE 9: REPORT RELEASE DATE 

Management has performed its final review of the financial statements through April 9,2014, the 

dale the financial statements were available to be issued. 

10 
4 

i 

5 

I EXHIBIT C 
Fotm 990 

Oc^artmert QI tha Irattjiy 

lni«m«l Sarwo 

Return of Organization Exempt From Income Tax 

Under lection 501(c|, S77, or 4947(a|(1| of the Itrtemal Revenue Code (eeccpl black lung 

bonofh truci or prlvale foundation) 

^ The organizBtion rruy have to use a copy of this telum to sately stale reporting requirements. 

0MB No. ISfWXX? 

»®12 

Open to Public 

Inspection 

C Name d orgaaianen American Conscrvsbve Union, inc 

OodB Bvsuioss As 52-0810813 

Nianbei and sirtcl <» P 0 ooa il mad is not Oenvo'od to sacei adaoss) 

1331 H SueelNW 

noom/uae 

500 202 347.9388 

CAy, town Of poll oliioo. alaic, and ZIP coda 

Washington, DC 30005 0 Gfoss leceofs S 10.377.133 

B Cno« ii ope cam' 

CD AOAfasi cnonga 

Q Namecnenga 

Q Initial relum 

• 'lemvnaied 

[Z1 Amonooo mvin 

Q Appiicalion pending 

Toa-eaemnl alalia D SOtlelOl 

FNameanaadOreuofpnneoololficcr Al Caidenas, Cfiairman 

1331 H Street WW. Washington. DC aOOOS 

BsOtieU * )< traennolDagayiaMtloi DMF 

J twaopha: • coftscrvatitre.org 

Fbd^ol etgingjfn 

Summary 

toaooeiion DOtiiei» 

M|e| It m paip mm IV i 

H|b|Aro as aKaotes included? •voa ONO 

It -Na,- anach a bst (see i.-BtnKicna) 

M|c| Group mempiion niatioer • 

I LYearoliowutcn 19M 1 MSlateollegaldomoie DC 

Briefly descnbc the organiziitlon's mission or most significant activities: ^e mieuon ol ite OrganizetionJsja^cpr^^ 

l?..??.'?.lP.?fly.??.l®Uip.RH^!'.^,fl!>9US.?lrirem wjal._f*pnpmiCj_a^^ 

(Part 

Check this boa b- Q if the organization discontini, 

Number of voting members ol the goveming bod 

Number ol independent voting members of the g&vcipia 

Total number ol individuals employed m calendar 

I Tola! number of volunleers (estimate if necossary 

! Total unrelated business revenue from Pari VIM, 

Net unrelated business taxable income from Porn' 

8 

e 

10 

11 

12 

itions opdii 

99 

fre than 25% of lis net assets. 

3 

yeal 2012 (Pan V. line 2a) 

srylg . MAY.j.B-ZOW 

, ctiRrtjn (C). line 12 

OlIPEN.Ul 

O 

Q 

w 

Contnbuiions and grants (Pan VIII. line lh). 

Program service revenue (Port VIII. line 2g) . 

inveslmenlincome pan VIII, column (A), lines 3, 4, and 7d) ... 

Other revenue (Part VMI, column (A), lines 5, 6d. Be, 9c, tOc, and 1 ie) 

Tolal revenue-add lines 8 through 11 (must equal Part VIII, column (A), line 12) 

7B 

7b 

PnorVur 

3,941.967 

465,994 

344,603 

4,773,564 

33 

31 

13 

100 

Cumni Vcsr 

6.48S.S03 

1,764,206 

37,414 

10,377.133 

13 Grants and Similar amounts paid Part IX, column (A), lines 1-3) . . . 

14 Benefits paid lo or for members (Part IX, column (A), line 4) .... 

15 Salaries, other compensation, employee benefits (Pan IX, column (A), lines 5-10) 

16a Professional lundraising lees (Part IX, column (A), line tie) 

b Total lundraising expenses (Part IX, column (D), line 25) b i|.3fi3<.705 

17 Other expenses (Part IX column (A), linos 11f>-11d, I1f-24ei 

18 Total expenses. Add lines 13-17 (must equal Pan IX. column (A), line 25) 

19 Revenue less expenses. Subtract lino 16 Irom line 12 

789,187 

3,704.665 

"33"" 

433,157 

9,780017 

10.694.076 

1416,9531 

U 

BctmninQ of CurrMit Tf tr M of Voir 

Total assets part X, hne 16) 

Total liaMilies (Part X, line 26) 

Net assets or fund balances. Subtract line 21 Irom line 20 

Signature Block 

1,663,689 1.155,307 

1,104,178 993.749 

576,511 161,558 

^ SlgnotuicoU _ . ^ 

gfcfcky Ov4.»c/op. T>re4llHirg< 

Typvwc 4 naire (ne ouo 

Paid 

Preparer 

Use Only 

tYuiVType pfcpni** name 

Thomas R. Conlon CPA 

vgioiiae Oile 

S'-l-H Cmdi 0 d 

s«n<«moM< 

r<nn'» .-safne » Conlon ft Assoctotes. LLC 

F»m-a odOroM » PO B0« 6213 Silver Spring. MP g09H-6213 

P014B600I 

Frni'sEIN O 

PhOrtOf® 301.59^6851 

a. 

May Ihe IRS discuss Ihis relum with the preparer shown above? (see InstAJctions) 2] Yes • Wo 

For Popenworfc Reduction Act Nobca, sec tlia separsle Instructions. CSLNO II3B2Y Fcnn99000131 
Foini990(?012| 52-0010813 Pii9e2 

!f-niiii statement of Program Service Accomplishments 

Check 11 Schedule O contains a response lo any qucsnon ir^ this Pan ill Q 

1 Brielly descnbe the organizaiion's mission: 

T.h«.n}!5S^on<M the p_rganjlsUpnijs.tocomrnunicalel.o,a.r^Jo educate 

Old the organization undertake any significant program services during the year wnich were not listed on the 

prtor Form 990 or 990-EZ? DYes (ZlNo 

If "-Yes," describe these new services on Schedule 0 

OK) the organization cease conducting, or make signHicant changes in how it conducts, any program 

services? . . DYCS IZINO 

If 'Ves," describe those changes on Schedule O. 

Oescnbe the organization's program service accomplishments for each of its three largest program services, as measured by 

expenses. Section 501(cX3) and 50tfc)(4) organizations are required to report the amount of grarits and allocations to others, 

the total expenses, and revenue. If any, lor each program service reported. 

4a (Code: ) (Expenses S including grams ol $ ) (Revenue S 1 

The Orqanliaiion communicaied lo ind educated the public about curtem soeiit. econemic, arvl poliucsl issues by providing 

4b (Code: ) (Expenses S ? '"eluding grams ol $ ) (Revenue $ ) 

Issues arid w.ceuuicJcderaland.staleeiKutiycs and tcgislstiye.bg 

4e (Code, ) (Expenses $ including grants of $ ) (Revenue S 

4d Other program services (Oescnbe m Schedule 0.) 

(Expenses S including grants of S ) (Revenue S ) 

4e Total program service expenses P e.612,S69 

Fenn B90 P0I2I 
Foini 990 |2U12| 52-0810813 P>gi3 

Checklist of Required Schedules 

10 

11 

e 

f 

12a 

13 

14 a 

t] 

15 . 

16 

17 

16 

19 

20a 

b 

Is Ihe ofganlzalion described in section 501(c)(3) or 4947(a)(1) (other than a pnvate foundation)? If "Vos," 

complete Schodule A 

Is the organization required to complete Schedule B, Schedule of Contributors (see instructions)? . . 

Did the organization engage in direct or indirect political campaign activities on tiehair of or in opposition to 

candidates (or public oflice? If "Yes/oornpfeta Schedule C, Part I 

Section 501(c)(3) organUations. Did the organization engage in lobbying activities, or have a section 501(h) 

election in effect during the tax year? If "yes.'complete Schedule C. Pari II 

Is the organization a seclion 501(c)(4). 601(c)(5), or 501(c)(6) organization that receives membership dues, 

assessments, or similar amounts as donned in Revenue Procedure 98-197 If 'Yes.' complete Schedule C, 

Pan III 

Old the organization maintain any donor advised funds or any similar funds or accounts for which donors 

have the right to provide advice on the distntiution or investment of amounts in such funds or aocounfs? If 

"Yes," complete Schedule D. Part i 

Did fho organization receive or hold a conservation easement, including easements to preserve open space, 

the environment, hstoric land areas, or historic stnjctures? If "Ves," complete Schedule 0, Part II . . . 

Did the organization maintain coliotnioris ot works ot an, hlstoncal treasures, or other similar sssets? If "Yes," 

complete Schedule D. Pad III 

Old the organization report an amount in Part X, line 21, for escrow or custodial account liability; senre as a 

custodian for amounts not listed in Part X; or provide credit counseling, debt management, credit repair, or 

debt negotiation servicos? If 'Yes,' complete Schedule D. Pari IV' 

Did the organizah'on, dtrecify or through a related organization, hold' assets in temporarily restricted 

endowments, permanent cndowmonls, or quasi-endowments? II "Yes,' complete Schedule O, Part V . . 

If the organization's answer to any of the following questions is 'Yes,' then complete Schedule 0, Parts VI, 

VII, VIII. IX, or X as applicable. 

Did the organization report an amount for land, buildings, and equipment in Part X, tine t07 If "Yes,' 

complete Schedule 0, Pad VI 

Did the organization report an amount for investments-other securities in Part X. line t2 that is 5% or more 

of ns total assets reported in Part X. line t67 It "Yes." complete Schedule D, Part vii 

Did the organization report an amount for investments-program related in Part X, line t3 thai Is 5% or more 

of rts total assets reported in Pari X, line 16? ff "Yes.' complete Schedule D, Pad Vlll 

Did the organization report an amount for other assets in Part X, line 15 that is 5% or more of its total assets 

reported in Pari X, line 16? If "Yes,' complete Schedule 0, Pad IX 

Did the organization report an amount for other liabilities in Part X, line 25? II 'Yes.'complete Schedule 0. Pad X 

Old Ilk) organization's separate or consolidated financial statements lor the lax year include a footnote that addresses 

Ihe organization's babiliiy for uncertain lax posmons under FIN 48 U^SC 740)? II yes.' complele Schedule 0, Pad X . 

Old Ihe oiganizalion obtain separate, independent audited Financial statements tor trie tax year? If 'Yes, * complete 

Schedule O. Pads XI end XU . 

Was the organization included in consolidated. Independent eudited financial statements for the (ax year? If "Yes,'and if 

the organzsbon answered 'No' to 'me f2a, then completing Schedule 0. Paris XI end XII a optional 

Is Ihe organlzabon a school described In seclion t7O(b)(i)(A}(i07 1/"Yes,* complefe Scheduled .... 

Old the organizatian maintain an office, employees, or agents outside ot the United States? 

Old the organization have aggregate revenues or expenses of more than $10,000 from grantmaking, 

fundraising, business, investment, and program service activities outside the United Slates, or aggregate 

foreign Investments valued at $100,000 or more? If "Yes.' complete Schedule F, Pads I and IV 

Old the organization report on Pan IX, column (A), line 3. more than $5,000 of grants or assistance to any 

organization or entity located outside the UnHed States? If "Yes," complete Schedule F. Pads II and IV .. . 

Old the organization report on Pari 0(, column (A), line 3, more than $5,000 of aggregate grants or assistance 

10 individuals located outside the United States? ff "Yes,* comp/efe Schedule P, Paris Iff and/V . . . 

Did the organization report a totaJ of more than $15,000 of expenses for professional lundraising services on 

ParilX, column (A), lines 6 and 11 e? " "Yes, • coriiptefe Schedu'e G, Pan' (Seo instrucifonsj 

Did the organization report more than $15.(XX1 total ot tundraising event gross income and contiitiutions on 

Pari Vlll, lines 1 c and 8a? // "Yes, * complete Schedule G, Pari //. . 

Did the organization report more than $15,000 ol gross income from gaming aciivities on Part Vlll, line 9a7 

If "Yes, * complete Schedule G. Pad III 

Old the organization operate ono or more tiosplia) laciitties? if "Yes," complete Schedule H 

If 'Yes' to line 20a, did the cyganization attach a copy oi its audited financial statements to this return? 

No 

1 / 

2 • 

3 / 

4 

S / 

6 / 

7 / 

a / 

9 / 

10 / 

11a / 

lib / 

lie / 

lid / 

lie / 

llf / 

12a • 

12b / 

13 / 

14a • 

14b • 

15 / 

16 / 

17 / 

16 / 

19 / 

20a • 

20b 

Form 990 POIZ) 
form 990 |20l2) 

Part IX 

52-0810813 Pap. 10 

Statement of Functional Expenses 

Section 501(c)(3) and 501(c)(<) orgaruations must completa aB columns. All Other organizations mjsl complete column (A). 

Da not Include amounts reported on lines Cb. 7b, 

8b. 96, and tOb of Part VIII. 

0 7 

8 

9 

10 

11 

a 

b 

c 

d 

e 

I 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

Giants and other assistance to governments and 

organizations in the United States. See Part IV. tine 71 

Grants and otner assistance to individuals in 

the Uniied States. See Part IV, line 27 . . . 

Grants and other assistance to governments, 

organizations, and indnriduals outside the 

United States. See Part IV. lines ts and t6 . . 

Benefits paid to or lor members .... 

Compensation of cunrent officers, directors. 

tnjstees, and key employees 

Compensation not included above, to disquatified 

persons (as defined under section 49S8(fX1)] and 

persons descrAied in section 49S8(c)(3](B) . . 

Other salaries and wages 

Pension plan accnials and contnbutions (include 

section 40t(k) and 403(b) employer contntwlions) 

Otner employee benefits 

Payroll taxes 

Fees tor services (non-employees). 

Management 

Legal 

Accounting . ... ... 

Lotibying 

Prolessional tundraising sennces. See Part IV, line t' 

Investment management toes 

Other. (It tne 1 tg amount nceeds tOK of tme 2S. column 

(4)amouni.lisltne tig expenses onSctibdiXeO.) . . 

Advertising and promotion 

Otficc expenses 

inlormation technology 

Royalties 

Occupancy 

Travel 

Payments of travel or entertainment expenses 

tor any federal, stale, or local public officials 

Conferences, conventions, and meetings 

Interest 

Payments to affiliates 

Depreciation, depletion, end amortization 

Insurance 

Other expenses. Itemize expenses not covered 

above (List miscellaneous expenses m line 24e. If 

line 24c amount exceeds lOM of fine 25. column 

(A) amount, list tne 24e expenses on Schedule .00 

0 

IA> 

TSUI eipcnsK 

IBI 

Piogiiun service 

cipeiMs 

(C) 

Fundnamg 

wjeiBaa 

215.000 161.250 32,250 21.500 

574,187 433,403 38,t17 102,667 

80.936 61.026 7,203 12.707 

53.743 40.522 4,783 8,438 

105,881 0 105.881 0 

13.554 0 13.554 0 

54.600 54.600 0 0 

211.264 179.831 3.850 27.583 

49.423 30.000 19.423 0 

133.979 41,605 92.374 0 

50.339 4.304 4B.03S 0 

154,950 116,832 13.791 24.327 

200,883 151.466 17,879 31.538 

2,540,947 2,261,347 279,600 0 

2,104 0 2,104 0 

33,978 0 33,978 0 

11.380 0 11,380 0 

B Potliical donations 1,710,000 1.710.000 0 0 

b Olieef mall 4,372,056 3.366,463 0 1,005,573 

c 

d 

e All other expenses 

25 Total lunctianBi experai^ Add bne i through ite 10.694.076 8.612,669 722.202 1,159,205 

26 Joint costs. Complclo this line only If the 

organization reponcd I'n column (B)' foint costs 

from 8 combined cducaixMial campaign and 

lundraisng solcnabon. Check nsre b' Q It 

lollovring SOP 96-2 (ASC 958-770) . . . . 4.372J)56 3,366,483 0 1,005.573 

Form 990 (ZOtZ) 
I 

SCHEDULEC 

(ForTTi990or990-EZ) 

Oepaimem el (h« Tieasur> 

intanal Revenue Service 

Political Campaign and Lobbying Activities 

For OrsanUatlons Exempt From Income Tax Under section SOl^c) and section 527 

e Complete if trie organization Is described below. • Attach to Form 090 or Form 090-EZ. 

b Sec sepaiale instructions. 

OMBNo. IMSOOZ? 

^©12 

Open to Public 

Inspection 

If dw organization answerod "Ves." to Form 990, Part IV, line 3, or Form 990-EZ, Part V, line 06 IPolKical Campaign Activtties), then 

• Soction S01ICX3) organizauons' Complete Pads l-A and B Do not complete Port l-C 

• Section SOi|c|(oiriti ttian section SO I(c|(3)) organizations' Complole Parts l-Aano C below. Oo not complolc Port 1-6. 

• Section 527 oiganlzations' Compleie Part l-A only 

It the organization answered "nres,* to Form 990, Part IV, line 4, or Form 990-E2. Part VI, line 47 (Lobbying Activities), Iben 

• Section 50I(C|I3) organizations mat have filed Fomi 5768 (election undei scciein SOt(>i))' Complete Part ll-A Oo not compleie Part ll-B 

• Section SOKcllS) oiganizalions mat hove NOT nicd Form 5760 (oloction under section SOi(h)). Compleie Part ll-B. Oo not complete Part ll-A. 

«the organization answered "Ves." to Form 090. Part IV. line 5 (Proxy Tax) or Form 900-EZ, Part V, line 3Sc (Proxy Tax), then 

« SeeUon 50i (cM), (5), or (6) oftianlzatlons Compleie Part iii 

Name of organization 

American ConsetvallVG Union. Inc. 

Part l-A 

Employer identnication number 

52-0810813 

Complete K the organigation is exempt under section 501(c) or is a section 527 organization. 

Provide a dcscriplion of the organization's direct and Indirect polilical campaign activillos in Part IV. 

Political expenditures 

Volunteer hours . . 

Part l-B 

1 

2 

3 

4a 

b 

Complete if the organization is exempt under section 501 (c)(3). 

Enter ihe amount of any excise lax incurred by the organization under section 4955 . . 

Enter the amount of any excise tax incurred by organization managers under section 4955 

II Ihe organization incurred a section 4955 tax. did it lile Form 4720 lor Ihis year? . . . 

Was a correction made? 

II "Yes." describe in Part IV. 

P> S 1.710.000 

-nve»~""nNo 

• Yes • No 

Part l-C Complete if the organization is exempt uncier section 501(c), except section 501(c)(3). 

Enter Ihe amount directly expended by the filing organization lor section 527 exempt function 

activities •$ 0 

Enter the amount ot the hling organization's funds conlnbuted to other organizations tor section 

527 exempt lunction ectlviiies ^ S i.7ip,000 

Total exempt function expenditures. Add lines l and 2 Enter liere and on Form 1120-POl, 

line 17b • S_ 

Did the tiling organization fife Form t120-POL for this year? "O Ves [7] No 

Enisr the names, addresses and employer identiflcaiion number (EIN) of all section 527 political organizations to which the filing 

organization made payments. For each organization listed, enter the amount paid from the filing organization's funds. Also enter 

the amount ot political contnbutions received that were promptly and directly delivered to a separate polilical organization, such 

as 0 separate segrogsted fund or a potitical action committee (PAC) II additional space is needed, provide information in Part tV. 

|i) Nznw (b) AdOnst le) EIN Id) AineunI pad tam 

fihiiQ orearvzxtion's 

funds 11 none, creer 4). 

te) Amount olpolacel 

oontnbuldns leoeivod end 

onmpiiyanddncey 

ddiverad le a scptniio 

none. enIB -0-

(t) 

Now Of Never PAC Kanses City, IMO 64116 45-4582149 0 1.110.009 

12) 

(3) - - -

(4) - -

(5) -

(6) - - -

For Papcrwoik ftcduction Act Nobce, see the tnsbuctions for Fomi 990 or 090-EZ. Cai No scoazs SmadiOe C (Fonm 990 a 990-82) »IZ 
Sehediil0 C (Form 990 ot 990-eZ) Mi? 

Part ll-A 

52-0810813 "•9'2 

Complete if the organization is exempt under section S01(c)(3) and filed Form 5768 (election under 

section 501 (h)). i 

A ChecK • • it ttie filing organization belongs to an affiliated group (and list in Part IV each affiliated group memlier's 

name, address. EIN, expenses, and share of excess lobbying expenditures). 

B Check • • if the filioq organization checked box A and "iimited conuor provisions apply. 

I 

4 

Limits on Lobbying Expenditures 

{The term "expenditures' means amounts paid or Incurred.) 

1a Total lobbying expenditures to influence public opinion (grass roots lobbying) .... 

b Total lobbying expenditures to influence a legislative body (direct lobbying) 

c Total lobbying expenditures (add lines la and tb) 

d Other exempt purpose expenditures 

e Total o'xempi purpose expenditures (add lines ic and Id) 

I Lobbying nontaxable amount. Enter the amount from the foHovrlng table In both 

columns. 

tr the omeuni on line la, column Is) or (b) Is: 

HOI over S500.000 20% ol iho emount on lino te 

Ovei SSOO.OOO but not over SI .000,000 $100,000 plus 15H ot ino excess over SSOO.OOO 

Over SI .000,000 but not over S i .500.000 SI 7S.OOO plus 10St of iho excess over Si .000.000. 

Over S1.SOO.000 but not over St7.OQO.O0O S22S.OOO plus i% ot irta excess over St.SOO.OOO. 

Over SI7.000.000 Si .000.000 

la) Fding 

cipaniuiian's totals 

MAIKiUoa 

group tores 

g Grassroots nontaxable amount (enter 2S% ol line It) 

h Subtract line lg from line la. II zero or less, enter -0-

i Subtracliinc If from line 1c. If zero or less, enter-0-

I If there is an amount other than zero on either llrtc th or line ti. did the organization lite Form 4720 

reporting section 4911 tax for this year? DVes QNo 

4>Year Averaging Period Under Soetion SOI |h) 

(Some organizations that made a section 501 (h) election do not have to complete all of the five 

columns below. See the Instructions lor lines 2a through 2f on page 4.) 

Calendar year (or riscal year 

bqinning in) 

(a) 7009 (b) 2010 to 2011 (d)20l2 (el Total 

2a Lobbying nontaxable amount 

b Lobbying ceiling amount 

(150% ol line 2a. column (e)) 

c Total lobbying expenditures 

d Grassroots nontaxable amount 

e Grassroots ceiling amount 

(150% ot tine 2d. column (e)) 

SehoOulo C (Tom eso «r geO-EZ) 3012 
8 

Senoduie C fann WO o. 080-62) 801? 52-0810813 

Complete if ttie organization Is exempt under section 501(c)(3) and has NOT Tiled Form 5768 

Page 3 

Part ll-B 

(election under section S01(h)). 

For each "Yes," response to lines la through li below, provide in Part IV a detailed 

description ol the lobbying activity. 

1 Ounng the year, did the tiling organization attempt to influence toreign, national, state or local 

legislation, including any attempt to influence public opinion on a legislative matter or 

referendum, through the use pi: 

a Volunteers? 

b Paid staff or management (include compensation in expenses reported on linos 7c througfi I i}7 

c Media advertisements? 

d Mailings to members, legislators, or the public? 

e Pubticaiions, or published or broadcast statements? 

f Grants to other organizations lor lobbying purposes? 

g Direct contact witli Icgelators, their statts, government officials, or a legislative body? . . . 

h Rallies, demonstrations, seminars, conventions, speeches, lectures, or any simitar means? . . 

I Other activities? 

J Total. Add tines lc through II 

2a Old the activities in tine t cause the organization to be not described in section S0t(c)(3)? . . 

b If "Yes," enter the amount of any tax incurred under section 49 7 2 

c If "Ves," enter the amount of any tax incurred by organization managers under section 4912 

d It ttio filing organization incurred n section 4912 tax, did n flic form 4720 tor this year? . . . , , 

i«TiiiiPjS Complete if the organization is exempt under section 501 (c)(4), section 501(c)(5}, or section 

501(c)|6). 

t Were substantially all (90% or more) dues received nondeductible by members? 

2 Did the organization make only in-house lobbying expenditures ot S2,000 or less? 

3 Did the organization agree to carry over lobbying and political expenditures from the prior year? 

Parttil-B 

Yes No 

1 • 

2 • 

3 • 

Complete H ttie organization is exempt under section 501(c)(4), section 501(c)(5), or section 

501(c)(6) and H either (a) BOTH Part lil-A, lines t and 2, are answered "No," OR (b) Part Ili-A, line 3, is 

answered "Yes." 

b 

c 

3 

4 

Dues, assessments and similar amounts from members 

Seciion 162(e) nondeductible lobbying and politicai expenditures (do not Include amounts of 

political expenses for wtilch the section S27(() tax was paid). 

Current year 

Carryover from last year .... 

Total 

Aggregate amount reported in section 6033(e)(1)(A) notices ot nortdeductit>ie section 162(e) dues . . 

It notices were sent and the amount on line 2c exceeds the amount on line 3, what portion of the 

excess does the organization agree to carryover to the reasonable estimate of nondeductible lobbying 

and political expenditure next year? 

Taxable amount of lobbying and political expenditures (see instrudions) 

2B 

2b 

Supplemental Information 

Complete this part to provide ttie descnptions required for Part l-A, tine 1, Part 1-8, line 4; Pan l-C, line 5; Pan ll-A (affiliated group 

list); Pan ti-A, line 2; and Pan ll-B, line i. Also, complete this pan for any additional informatnn. 

Seliadulc C fTean 9W or 9S0-fZ) MtZ 
9 

SCHEDULE 0 

(Form 090 or 990-EZ) 

Oepanmsni of ihg Tnusuf> 

Iniunai Revenue SenHoc 

Supplemental Information to Form 990 or 990-EZ 

Complete to provide Informabon for responses to speciflc questions on 

Form 090 or 990-EZ or to provide any additional Information. 

P Attach to Form 990 or 990-EZ. 

SCHEDULE 0 0MB No 1Sa$l<!C47 

(Form 090 or 990-EZ) 

Oepanmsni of ihg Tnusuf> 

Iniunai Revenue SenHoc 

Supplemental Information to Form 990 or 990-EZ 

Complete to provide Informabon for responses to speciflc questions on 

Form 090 or 990-EZ or to provide any additional Information. 

P Attach to Form 990 or 990-EZ. 

i(0)12 • 

SCHEDULE 0 

(Form 090 or 990-EZ) 

Oepanmsni of ihg Tnusuf> 

Iniunai Revenue SenHoc 

Supplemental Information to Form 990 or 990-EZ 

Complete to provide Informabon for responses to speciflc questions on 

Form 090 or 990-EZ or to provide any additional Information. 

P Attach to Form 990 or 990-EZ. 

Open to Public 

Inspection 

Name ol ma osansaiion 

American Conservative Union, inc 52-0910813 

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