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FEDERAL ELECTION COMMISSION

Blc; '" SIIUET N.W.

WASHINCTON,DC. 204&3

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r-tarch 27, 1979

Mr. Robert J. Litshutz, Treasurer

Committee for Jimmy Carter

1600 Pennsylvania Avenue

Washington, D.C. 20500

Dear Mr. Lipshutz:

Enclosed for your information is a copy of the final

audit report. of 'th'e' Committee for Jimmy Carter (Primary

Election) which was approved by the Commission on March 22,

1979.

Upon notice by return receipt that your informational

copy of the report has been received (within approxi~ately

five days), it will be issued publicly by the Commission.

Should you have any questions regarding the public

release of this report, please contact Mr. Fred Eiland of

the Commission's Press Office at (202) 523-4065. Any

questions you may yet have related to matters covered during

the audit or in the audit report should be directed to

Mr. Joseph Stoltz of the Audit Division at (202) 523-4155 •

~'.~:z.....lIII"'"~o:."'llo.. ROber1asta ASSi~ ~iaff Director

for the Audit Division

Enclosure as stated

CERTIFIED :-L~IL:

RETUR~ RECEIPT REQCESTED
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FEDERAL ELECTION COMMISSION

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March 27, 1979

The Honorable Jimmy Carter

The tihi te House

1600 Pennsylvania Avenue

Washington, D.C. 20500

Dear Mr. President:

Enclosed for your informa.t,i.,OD,is.~ copy of the final

audit report of the Committee for Jimmy Carter (p'rlmary

Election) which was approved by the Commission on March 22,

1979 •

Upon notice by return receipt that your informational

copy of the report has been received (within approximately

five days), it will be issued publicly by the Commission •

Should you have any questions regarding the public

release of this report, please contact Mr. Fred Eiland of

the Commission's Press Office at (202) 523-4065. Any

questions you may yet have related to matters covered during

the audit or in the audit report should be directed to

Mr. Joseph Stoltz of the Audit Division at (202) 523-4155.

~~""t-a~""" Assistant Staff Director

for the Audit Division

Enclosure as stated

CERTIFIED :·IAIL:

RETU~J RECEIPT REQUESTED

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FEDERAL ELECTION COl\"J\1ISSION

ll~S KSTREET N.W.

W.~SHINCTON.DC. 20463

March 27, 1979

Ronald Eastman, Esquire

Cadwalader, Wickersham & Taft

Eleven Dupont Circle

Washington, D.C. 20036

Dear Mr. Eastman:

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Enclosed for your information is a copy of the final

audit report--ofthe -Committ_ee JQ_r ;r~Jt~~y Carter (Primary

Election) which was approved by the Commission on -~tarcn 2-2,

1979.

upon notice by return receipt that your informational

copy of the report has been received (within approximately

five days), it will be issued publicly by the Commission •

Should you have any questions regarding the public

release of this report, please contact Mr. Fred Eiland of

the Commission's Press Office at (202) 523-4065. Any

questions you may yet have related to matters covered during

the audit or in the audit report should be directed to

Mr. Joseph Stoltz of the Audit Division at (202) 523-4155.

$L._~~_ Assista~~:~f Robert r-~a Director

for the Audit Division

Enclosure as stated

CERTIFIED ~lAIL:

RETU&~ RECEIPT REQUESTED
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FEDERAL ELECTION COMMISSION

H.!r) l)lIUE T N W.

"',\".II\iC TON. 0.(. 2046 \

REPORT OF THE AUDIT DIVISION

ON

THE COMMITTEE FOR JIMMY CARTER

(Primary Election)

I. Background

This report covers an audit of the Committee for Jimmy

Carter, undertaken by the Audit Division, to determine whether

there has been compliance with the pro~isions of the Federal

Election Campaign Act of 1971, as amended (tithe Act"). The

audit was conducted pursuant to Section 438(a) (8) of the Act

and Section 9.038,(a) _o,f Ch~pter 96 of the Internal Revenue Code

of 1954. Section 438 (a) (8) a-f'the Act'di'rec't's 'the Commission

"to make from time to time audits and field investigations with

respect to reports and statements filed under the provisions of

this chapter, and with respect to alleged failures to file any

report or statement required under the provisions of this chapter,

and to give priority to auditing and field investigating of the

verification for, and the receipt and use of, any payments received

by a candidate under Chapter 95 or Chapter 96 of the Internal

Revenue Code of 1954." Section 9038(a) of Chapter 96 states that

"after each matching payment period, the Commission shall conduct

a thorough examination and audit of the qualified campaign expenses

of every candidate and his authorized committees who received

payments under Section 9037."

The Committee for Jimmy Carter served as the principal campaign

committee of the candidate, James E. Carter, during the primary

election period. Its principal officers during the period covered

by the audit were Mr. Philip Alston, Jr., Chairman, and Mr. Robert

J. Lipshutz, Treasurer•

The audit covered the period January 1, 1975, the effective

date of the Act, through June 30, 1978. The Committee reported

opening cash of $16,376.57, total receipts of $14,635,161.66,

total expenditures of $14,648,080.72 1/ and closing cash of

$3,456.72 during the period. -

1/ The Committee reported a total expenditure amount subject

to limitation of $10,033,856.50 •

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-2-

II. Findings and Conclusions

This report is based on documents and working papers

supporting each of its factual statements. They form part of

the record upon which the Commission based its decisions on the

matters in this report and were available to Commissioners and

appropriate staff for review.

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A. Disclosure of Purpose and Payee of Expenditures

Introduction

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Section 434(b) (9) of Title 2 of the United States Code

provides in part that each report under this section "shall

di-sclose--the-ident-i-ficat-ion -of -each pe_J::'$__9Jl __ 1:.9 whom expenditures

have been made by such conunittee or on behalfo-f sucn-commi-t-teeor candidate within the calendar year in an aggregate amount or

value in excess of $100.00, the amount, date and purpose of each

such expenditure ••. " In addition, on September 29, 1976, the

CJrnmission informed candidates and co~~ittees that a general

description of the purpose of expenditures was insufficient to

meet the requirements of the Act. Subsequently, the then

proposed regulations were amended to include a requirement that

the particulars of expenditures be shown on disclosure reports.

(See 11 CFR 104.2 (b) (9» •

Discussion

In our test of Co~mittee expenditures, certain groups of

expenditures were noted where the purpose and/or amount appeared

to be inconsistent with the reported payee. For example, amounts

paid to business entities for "personal expense reimbursements",

"refundable deposits" paid to individuals, and large expenditures

for "meeting: fundraising" were identified. Further review of t:te

supporting documentation of these expenditures showed that the

disclosure of the items was not always adequate.

As a result of this initial review, four major categories

of expenditures were identified for closer study. Of the 284

expenditures tested, 211 fell within these four categories, a~d

9S were :ound to be inadequately disclosed.
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A discussion of each of the four categories follows:

a) Personal Expense Reimbursements

There were 66 items which were disclosed as personal

expense reimbursements. Thirty-eight of the,se were considered

disclosed improperly. Nine of the 38 were payments to business

entities, while the other 29 were paj~e~ts to individuals.

Examination of the supporting documentation for the

expenditures showed that, rather than reimbursement for personal

expenses, the reimbursement was for such expenses as advertisin£,

printing, and the replenishment of pe~~~' cash funds.

b) Meetings: ORG/Get Out the Vote

There were 70 expenditures identified in this~anher,

thirty-four of which were disclosed i~s~:ficiently. For example,

our review disclosed payments to indi·/i~uals for advances,

election day expenses, and the payme~t of rent classi!ied in

this r.1anner .

c) Meetings: Fundraising

Our review also included 52 expenditures disclosed as

"meetincs: fundraisino"; the indi·Jic'..lals and/or vendors orovidinc

goods and/or services ~ere not disclosed :or 13 of the 52· items J

reviewed. Instead, the person who received the funds from the

Committee to make the expenditures Nas disclosed. T~ese payments

represented items such as the purchase of promotional services,

printing of tickets, and salaries.

d) Refundable Deposits

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Twenty-three of the 284 ite~s ~ere disclosed as

expenditures for refundable deposits. ~e found that 14 of these

payments were used by the payee to ~ake deposits on o:fice space,

room deposits, and, in at least eigh~ ~~stances, :or telephone

deposits. Again, vendors providing se~~ices (i.e., phone company,

hotel, real estate agent, etc.) shcu:d have been disclosed •
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Conclusion

The disclosure of the expenditures discussed above was

incomplete in that there were less than accurate descriptions

of the actual purpose, and in many cases no identification of

the persons providing services to the campaign. We believe that

these inaccuracies in disclosure were the direct result of the

Committee's use of general ledger categories as the purpose for

its expenditures. However, it should also be noted that most of

the Committee's expenditure activity occurred prior to September

29, 1976, the date on which the Commission issued guidelines

requiring a more detailed disclosure of purpose and persons

providing services to the campaign.

Recommendation

since the rnajorit:(' of the Com.~i-t·tee's expenditures. wer~

made and disclosed prior to the September 29, 1976 guideline,

we feel requests :or amendments of this nature would not be

warranted at this time .

B. Improper Use of Depositories

Section 433(b) (9) of Title 2 of the United States Code

provides that the statement of organization required 0: a

political committee under Section 433(a) shall include a listing

of all ba~ks, safety deposit boxes or other repositories used.

Section 437b(a) (l) provides in part, that each candidate

shall designate one or more national or State banks as his campaign

depositories. The principal campaign committee of such candidate,

and an~l other political conunittee authorized by him to receive

contributions or to make expenditures on his behalf, shall maintain

a single checking account and such other accounts as the committee

determines to maintain at its discretion at a depository designated

by the candidate and shall deposit any contributions received by

such co~mittee into such account. No expenditure may be made by

any such committee on behalf of a candidate or to in:luence his

election except by check drawn on such account, other than pett~1

cash expenditures as provided in subsection (b). Section 432(b)

prohibits the commingling of all funds of a political committee

with any personal funds of officers, ~embers, or associates of

such cOr.'~i ttees•
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During the review of the Committee's records, we determined

that expenditures in support of the candidate had been made from

at least five (5) bank accounts which had not been disclosed on

the Committee's statement of organization or amendments thereto

as Committee repositories. Committee records show that the accounts

were held in the name of individuals who wer.e either employees of

the Committee or authorized to make expenditures on behalf of the

candidate. The records show the disbursement of Committee funds

to these individuals for a number of purposes including personal

expense reimbursements, miscellaneous administrative expenses and

meetings: fundraising. In some instances, these disbursements

drawn on other Committee accounts were deposited directly into the

undisclosed accounts. In other instances, Committee disbursements

could not be traced to deposits made to the undisclosed accounts

due to insufficient documentation in Committee records. However,

amount·s simila·r to· those disbursed .t.O each account holder were

disbursed from the accounts in questio~ ~~ ~~i~~~ the cost bf

campaign activity.

In addition, we found evidence to suggest that at least

three (3) of the holders of those account~ had commingled their

own personal funds with those of the Committee.

On February 7, 1973, the Commission found reason to believe

th3t violations of 2 U.S.C. 437b(a) (1), 433(b) (9) and 432(b) had

occurred and three (3) of these accounts were made the subject

of :-'lUR 484 •

The Committee was asked to disclose the other two (2) accounts

as campaign depositories. In one instance, the Committee complied,

but at the same time, the Co~~ittee's attorney noted that based

on the facts as the Committee understood them, the other account

was not a campaign respository under 2 U.S.C. 433. Consequentl~·,

the account in question was also referred to the Office of General Counse~ for considerat10n with MUR 484 •

On August 23, 1978, the Commission found reasonable cause

to believe that the Cornmi~tee failed to designate and disclose

four (4) campaign repositories in violation of 2 U.S.C. 43ib(a)

(1) and 433(b) (9). In a subsequent action on December 6, 1978,

the Corrmission retained its finding of August 23, and found
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reasonable cause to believe that violations of 432(b) had also

occurred in two (2) of the four (4) accounts. As a result, the

Committee entered into a conciliation agreement requiring the

payment of a $1,950.00 civil penalty. On January 4, 1979, the

Commission received a signed copy of the agreement and a check

for $1,950.00 which has been forwarded to the United States

Treasury. On January 17, 1979, the Commission approved the

agreement thereby closing the file on this matter •

c. Improper Disclosure of the Proceeds from Sale of Items

Introduction

Section l04.3(b), Code of Federal Regulations, provides in

part that contributions of stocks, bonds, art objects and other

similar items to be liquidated shall be reported as follows:

1) If the item has not bee~ liquidated at the close of a

reporting period, the committee shall record as a memo entry

(not as cash) the item's fair ma~ket value on the date received,

including the identification (a~~ h~ere in excess of $100.00,

the occupation and princ~pal place of business) of the contributor.

2) When the item is sold, t~e committee or candidate shall

record the proceeds. It shall report the (i) identification (and

where in excess of $100.00, the occupation and principal place

0: business) of the purchaser, i: ~u~chased directly from the

candidate or committee, in whic~ c~se he or she shall be considered to have made a contribut~=~, and (ii) the identification

of the original contributor.

Discussion

The Committee collected a tc~a: of $50,341.53 in proceeds

from the sale of contributed ite~s a~d disclosed the collections

as refunds/rebates. A Committee o:~icial stated that some of

the items were donated to the ca~;aign by various persons and

were then sold through a co~zcdi~ies exchange resulting in

proceeds of $33,337.93.

The remaining $17,003.60 resu:ted from an auction whereby

the Co~~ittee auctioned off ite~s ~o~ated ~o the campaign by

various persons. A Co~~ittee c::~=ial stated that the donation

cf each commodity was attributed to more than one person wheneve~

t~e market value of any item dc~a~ed exceeded $1,000 •
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! a accounting for t!-te contributed i -:ems, the Cornmi tt~

disclosed each i~em as an in-kind contribution with an

accc~panying expenditure in an amount equal to the sale pr~ce

~f each item sold.

The official responsible for preparing the Committee's

disclosure repo~~ stated he was unsure as to how such proceeds

should have been disC10~ed. Since an in-kind contribution and

accompanying expenditure had already been recorded, he disclosed

the proceeds as refunds. Since refunds are subtracted from

operating expenditures, he was able to avoid including the

amounts in the Committee's total expenditure figures a second

time.

Conclusion

Although-t-he Comrni ttee' 5 rne-thod of di-sclosing the abo'.te

items results in no misstatement of expenditures subject to

limitation, total receipts and expenditures are each overstated

by at least $50,341.53. In our opinion, the treatment of

liquidated non-cash contributions was incorrect, affecting the

accuracy of the Committee's total receipts, total refunds and

rebates, total operating expenditures, and total expenditures.

Recommendation

On January 9, 1978, the Commission directed the Committee

to amend its disclosure reports to comply ·/lith Section 104.3 (b)

of Title 11, Code of Federal Regulations. The Committee

subsequently filed an amended report cor~ecting the errors as

required. Therefore, we reco~.end no fur~her action be taken

on this matter.

D. Repayments to the United States Treasury

1) Apparent Unqualified Campaign Expenses

Section 432(d) of Title 2 of the G~ited States Code

requires the treasurer of a political co~~i~tee to obtain

and keep a receipted bill, stating the particulars, for every

expenditure made by or on behalf of a political co~~ittee in

excess of S100 in amount, and for any such expendit~re in a

lesser amount if the aggregate amount of such expenditure to

the same persc~ during a calendar year exceeds SlOO •

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Section 9038(b) (2) of Title 26 of the united States

Code provides that if the Commission determines that any amount

of any payment made to a candidate from the matching payment

account was used for any purpose other than

a) to defray the qualified campalgn expenses with

respect to which such payment was made; or

b) to repay loans the proceeds of which were used,

or otherwise to restore funds (other than contributions to defray

qualified campaign expenses which were received and expended) - which were used, to defray qualified campaign expenses, it shall

notify such candidate of the amount so used, and the candidate

shall pay to the Secretary or his delegate an amount equal to

such- amount •

In an attempt to determine whether the Committee

had obtained and kept receipted bills as required, we chose a

sample of items from the expenditure sections of the Committee's

reports and traced it to the Committee's records file. We found

that 67 of the 552 items tested, or approximately 12% of the i~0ns

sampled, were not supported by a receipted bill or an acceptable

contemporaneous memo as required. However, each of the 67 ite~s

was supported by a cancelled check •

In addition, the Committee used a Committee chec~

request voucher and a notarized statement in lieu of receipted

bills. These documents contained a check number, the account to

be charged and a general purpose for which the money was to be

spent. Each notarized statement had been endorsed by the payee

and included a clause stating the funds had been expended on

qualified campaign expenses. However, neither the Co~~ittee

request voucher nor the notarized statement showed an itemization

of expenses incurred. As we believed the rate of unsupported

items to be excessive, we expanded our testing procedures to

include a general review of the types of expenditures included

in the 67 expenditures noted above. We identified an additional

79 items supported with si~ilar documentation •
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On January 9, 1978, the Commission directed the

Committee to produce acceptabl~ documentation for the 146 items

identified. The Commission preliminarily determined that should

the Committee produce acceptable documentation to demonstrate the

expenditures connection to the campaign, no further fieldwork woulj

be required. However, it determined that should an acceptable

showing not be made, additional fieldwork would be required to

identify such other expenditures. In a separate compliance action

the Commission directed that 19 other expenditures totaling

$11,527.60 be added to the list of 146 items, bringing the total

number of items inadequately supported to 165 and the total dollar

value to $346,343.29 •

Pursuant to the Commission's request, the Committee

submitted documentation sufficient to establish connection with

the campaign for 62 of the 67 previously inadequately supported

expenditures noted in our sample. Thus, five (5) (approximately

one (1) percent of the items sampled) totaling $555.00 (less than

one (1) percent of the total amount sampled) remained unsupporteu

when_ the _Comm.i:ssion considered the Commi ttet-~' s efforts to comply

with its reqaest':-' At-that ti-me, the- ·Commission-determined· tha~

no further fieldwork was necessary, since it believed the

Committee's response to be an acceptable showing. In addition,

it determined that documentation supporting the remaining five (5)

items from the sample plus 16 others, :or which the Committee had

not submitted documentation, did not show a sufficiently detailed

purpose to establish connection with the campaign. Consequently,

the Commission determined that these 21 expenditures totaling

$6,072.60 were unqualified campaign expenses and were repayable

in full to the United States Treasury (see Attachment I).

Subsequent actions resulted in that amcunt bei~g revised downwa~d

to $5,872.60 •

In a letter dated October 12, 1978, the Committee was

provided 90 days to repay the amount discussed above. On January

4, 1979, the Audit Division received a check payable to the

United States Treasury for $5,872.60.

Recommendation

Since the Committee has paid the full amount as required,

we recommend no further action be taken on this matter•

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Refund of Excess Matching Funds

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Section 9038(b) (3) of Title 26 of the United States

Code states that if the Commission determines that any portion

of the payments to a candidate from the matching payment account

was in excess of the aggregate amount of payments to which such

candidate was entitled under Section 9034, it shall notify the

candidate, and the candidate shall pay to the Secretary or his

delegate an amount equal to the amount of the excess payments•

Section 134.3(c) (2) of Title 11, Code of Federal

Regulations, provides that if, on the last day of candidate

eligibility there are net outstanding campaign obligations, any

matching funds received thereafter may be retained for a period

not exceeding 6 months after the end of the matching payment

period in order to liquidate those obligations. However, as of

the date ,when__the,amQ~ntor amounts of matching funds received

after ineligibility equat-(s) Ehe a.rnount--'o'f--'e-he- -candidate,' sne-t

outstanding campaign obligations, the candidate shall be obliged

to repay to the Treasury that portion of any unexpended balance

remaining on that date in the candidate's accounts (less the

matching payments so received), which bears the ~aoe ratio to

such balance as the total amount bears to the aggregate of all

contributions and matching funds deposited in all the depositories

through that date.

As of July 14, 1976, the date on which the Commission

determined to be the candidate's ineli~ibility date, the Committee

had net outstanding campaign obligations of $1.32 million.

Net matching funds received after that date totaled $.81 million. ~/

Since the amount of matching payments received after the date of

ineligibility was not equal to or in excess of the candidate's

net outstanding campaign obligations, no repayment of excess

matching funds is required.

Recommendation

The Audit staff recommends that no action be taken with

respect to this matter.

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•

~/ This amount consists of 5933,086.00 in matching payments

paid to Candidate post July 14, 1976, minus a voluntary

refund on August 29, 1977 of $126,515.00 •
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-11-

III. Auditor's Statement

Except for the matters specifically noted in this report,

the audit disclosed that the Committee for Jimmy Carter conducted

its activities in conformity with the Federal Election Campaign

Act of 1971, as amended, and in conformity with Chapter 96 of

Title 26, U.S.C., in all material aspects .
Attachment I, page 1 of 2

EXPE~DITURES FOUND TO BE INSUFFICIE~7LY DOCG~E~TED BY A~DI:

A.\10U~T MI0UNT

PAYEE DATE fu'\10UNT SUPPORTED UNSUPPORTED PGRPOSE

.--',

.-

Individual 5/11/76 . 200.00 0 200.00 election day

transit, CT

Individual 5/11/76 200.00 0 200.CC election day

transit, tT

Individual 4/26/76 800.00 0 800.00 election day ex.

Individual 4/26/76 ~60.00 a 460.00 get out vote

Individual 4/26/76 780.00 0 780.00 get out vote

Individual 5/28/76 800.00 452.40 347.60 LA meeting, r~lexican American

Individual 12/31/75 300.00 0 300.00 Advances other

. e,. ."~' !::: :~~.;.~.:. ':~:,7'~ -~ .. - 11 • • ••'

t- ~: .. .. .,. ."'~/~••-: ..- .... -;~ ...I

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~~

J>j\YEE

Individual

Individual

Individual

Individual

Individual

Individual

Organization

Total

Attachment I, page 2 of 2

EXPENDITURES FOUND TO BE I~SGFFICIE~TLY DOCU~ENTED BY A~DIT

1'~'\10L~:,:r~ l\NOU:~J:'

Dl\TI.; i~·I(jC~;T SUPPOETE8 t.:::SUPPORTED p"~.~? :.s:: --

1/23/76 $ 100.00 0 $ 100.00 Perso~a': E:·:p.

reir.-.burs ernent

1/26/76 580.00 0 580.00 :1tgs. ORG-GOTV

5/17/76 750.00 0 750.00 Personal Exp.

reimbursement

1/4/76 25.00 0 25.00 Personal Exp.

reirnburseI'!"l.ent

3/12/76 100.00 0 100.00 Personal E:<p.

reirnburser.1ent

4/7/76 25.00 0 25.00 Personal E,,:p.

reir.".bursc::'.en t

4/26/76 205.00 a 205.00 Consulta:lt Fees

5/21/76 1,000.00 0 ~OOO.OO .. .. . .n.c.~la:-.ces ot::e~

$6,325.00 $452.40 $5,872.60

.......,.:...........

e ~~'-'f""- ••• "; .. .. ~~... ..-.,._.....

• \ .•. f· ----... -

-
•

•

FEDERAL ELECTION COM~\lSSION

1\25 1\ SIIU 1 '- \\'.

\'J.-\SHI~G 101\;.() r. 204h \

AlDrrIONAL INFORMATION REG\RDING '!HIS ORGANIZATION

MAY BE lOCATED IN A OOMPLETED COMPLIANCE ACIION

FnE--RELEASED BY--9 a:M1:tSSION AND MADE- PuBLIC m

'!'HE PUBLIC REOORDS OFFICE. FUR '!HIS PARrICULAR

ORGANIZATION'S <n1PLETED OOMPLIANCE ACTION Fn.E

SlMPLY FUR THE PRESS SUt+1ARY OF MlJR 41 1'&t

'l1iE PRESS Sl'M1ARY WIIL PROVIDE A BRIEF HIS'roRY OF

'!BE CASE AND A sm+fARY OF 'mE ACTIONS TAKEN, IF N:ri•