FEDERAL ELECTION COMMISSION

Washington, DC 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) 

Friends of Bill Posey ) MUR 7707

 and Nancy H. Watkins in her official capacity as treasurer ) 

Bill Posey ) 

American Muscle Car Museum, Inc. ) 

Mark Judson Pieloch ) 

Tetiana Pieloch ) 

 ) 

 

STATEMENT OF REASONS OF CHAIRMAN ALLEN J. DICKERSON

In this Matter, the Commission considered whether congressional candidate Bill 

Posey and his authorized committee, Friends of Bill Posey (the “Committee”), accepted 

prohibited and excessive contributions from the American Muscle Car Museum, Inc. (the 

“Museum”), which hosted three of the Committee’s campaign events in 2018 and 2019.1 We 

also considered whether the Committee failed to report contributions raised or expenditures 

made in connection with these events, and whether the Museum improperly denied the 

Complainant’s request to host a similar campaign event.2

I chose to dismiss this Matter for the reasons described in the Factual & Legal 

Analysis unanimously approved by the Commission—chiefly because the dollar value of the 

alleged violation does not appear to be significant.3 However, Respondents have a right under 

52 U.S.C. § 30109(a)(2) and 11 C.F.R. § 111.9 to further clarification of the facts and 

inferences that were material to my vote. 

Commission regulations squarely address campaigns’ use of corporate facilities or 

resources for campaign events.4 Here, the corporation—the Museum—is a nonprofit, and the 

real property where it is located and virtually all the cars it displays appear to be owned by 

an individual, Mark Pieloch.5 According to both the Museum’s Response and IRS records, the 

Museum did not pay Mr. Pieloch for the use of his property during the time period at issue 

1 Factual & Legal Analysis at 8–11, MUR 7707 (Friends of Bill Posey, et al.). 2 Id.

3 Id. at 11. 4 See 11 C.F.R. §§ 114.9; 114.13.

5 See FL. DEP’T OF STATE DIV. OF CORPS., ARTICLES OF INCORPORATION: AMERICAN MUSCLE CAR 

MUSEUM, INC.,

https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C2016

%5C0203%5C80063057.Tif&documentNumber=N16000000965; Museum Resp. at 1–2. 

MUR770700103
MUR 7707 (Friends of Bill Posey, et al.) 

Statement of Reasons

Page 2 of 2 

2 

in this Matter, nor does the Museum charge other organizations a fee for their use of the 

property for events.6 We have no information before us calling this into question. 

I have previously expressed my concern that the Commission is insufficiently 

attentive to the law governing corporations.7 Similarly, here, while the Factual & Legal 

Analysis correctly states the Commission’s analysis, I write separately to emphasize the 

distinction between Mr. Pieloch as an individual and the Museum as a separately 

incorporated entity in Florida. 

Although the Complaint notes that both Mr. and Mrs. Pieloch contributed the 

maximum amount to the Posey campaign for the primary and general elections during the 

2018 and 2020 election cycles,8 it does not allege that the Pielochs used the Museum as an 

alter ego or “straw” donor. The decision to add them as Respondents in this Matter seems to 

have been made by the Commission upon receipt of the Complaint—not by the 

Complainant9—and neither the MUR record nor the Factual & Legal Analysis provides the 

legal basis for this decision. Moreover, while the record before us suggests that Mr. Pieloch 

provides the Museum with both real and personal property for its exclusive use and manages 

the Museum’s affairs as its President,10 such unremarkable arrangements are insufficient to

make the Museum a legal alter ego of Mr. Pieloch. 

When the Commission is presented with respondents that are treated as separate 

taxable entities under the Internal Revenue Code, it should be vigilant in avoiding language 

that could unduly imply that such respondents are, de facto, one and the same. For these 

reasons, as well as the reasons stated in the Factual & Legal Analysis, I voted to dismiss this 

matter. 

March 9, 2022 

Date

___________________________ 

Allen J. Dickerson 

Chairman

6 See 2019 FORM 990EZ, AMERICAN MUSCLE CAR MUSEUM, INC., available at 

https://apps.irs.gov/pub/epostcard/cor/812511794_201912_990EZ_2021050418054757.pdf, and 2018 

FORM 990EZ, AMERICAN MUSCLE CAR MUSEUM, INC., available at

https://apps.irs.gov/pub/epostcard/cor/812511794_201812_990EZ_2019081616573473.pdf; see also

Museum Resp. at 2–3. 

7 See, e.g., Statement of Reasons of Vice Chair Allen Dickerson and Comm’rs Sean J. Cooksey and 

James E. “Trey” Trainor, III, MUR 7180 (GEO Holdings, Inc., et al.) (addressing the concept of “alter 

ego” in the context of alleged violations of the Act.). 8 Compl. at 9.

9 See Pieloch Resp.

10 See Museum Resp. at 1.

MUR770700104