• FEDERAL ELECTION COMMISSION

December 16, 1980

MEMORANDUM

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TO:

THROUGH:

FROM:

SUBJECT:

FRED EILAND

PRESS OFFICE

BOB COSTA

RICK HALTER

PUBLIC ISSUANCE OF FINAL (POST-PRIMARY)

AUDIT REPORT OF THE DOLE FOR PRESIDENT

COMMITTEE

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Attached please find a copy of the final audit report

(llost-primary) of the Dole for President Committee which was

.lpproved by the Commission on November 6, 1980.

Informational copies of the report have been received

by all parties involved and the report may be released to

the public as of today, December 16, 1980.

Attachment as stated

cc: FEC Library

RAD

,Putlic R(:cord
The Committee registered with the Federal Election

Commission as the principal campaign committee for the Honorable

Robert J. Dole on Fcbru~ry 21, 1979. 1/ The Committee maintained

its headquarters in Alexandria, Virginia.

REPOHT 01" TilE AUDIT DIVISION

ON

THE DOLE FOR PRESIDENT COMMITTEE, INC.

WASt·t1'OC TO~ () C ~04h \

FEDERAL ELECTION COl\1MISSION

Background

A. Overview

In addition, section 9039(b) of Title 26 of the United

States Code and Section 903B.l(b) of Title 11 of the Code of

Federal Regulations state, in relevant part, that the Commission

may conduct other examinations and audits from time to time

as it deems necessary.

!-/ 'rhe Committee registered as the Dole For President (Explor~lori'

Conlmittce) on February 21, 1979. Successor committee nawcs

arc Dole For President Co~~iltee and Dole For President

CO::'.l:li t tee, Inc .

I.

This report is based on an audit of the Dole

For President Conunittee, Inc. ("the Committee"), to determine

whether there has been compliance with the provisions of the

Federal Election Campaign Act of 1971, as amended ("the Act").

The audit was conducted pursuant to Section 9038(a) of Title 26

of the United States Code which states that "after each

matching payment period, the Co~nission 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."

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The audit covered the period from rllception through

March 27, 1980, the date determined by the Commission-to be

the date of ineligibility for purposes of incurring qualified

campaign expenses. 2/ At the time of the completion of the

audit, the Committee had reported its financial activity through

F~bruary 29, 1980. That activity plus our reconciliation of

the activity for the remainder of the period through March 27,

1980, revealed the following:

This report is based upon documents and working (l.lpers

which support each of the factual statements. They form part of

the record upon which the Commission based its decisions on the

matters in the report and were available to Commissioners and

appropriate staff for review.

-- B.

Opening Cash Balance

Total Receipts

Total Expenditures

Closing Cash Balance

Key Personnel

$ -0-

1,421,330.38

1,393,290.48

34, 659 • 7 3 'i/

The principal officers of the Committee during the period

audited were Gerald Nash, Chairman and Ann Dare McLaughlin, Treasurer.

C. Scope

The audit included such tests as verification of reported

receipts, expenditures and individual transactions; review of required

supporting docume~tation; analysis of Committee debts and obligations;

review of contribution and expenditure limitations and such other

audit procedures as deemed necessary under the circumstances.

II. Audit Findin0s and Recommendations

On August 1, 1980, the interim post-primary audit report was

received bv the Committee for response within 30 days of receipt.

On August i2, 1980, thG Committee requested a 30 day extension of

the response ti~c due ~o the need for additional time to obtain

copies of cancelled cashier's checks and because minor time-related

problems were encountered with vendors. The Commission, on August

19, 1980, denied the Cc~mittee's request for a 30 day extension of

time to respond to the interim post-primary audit report. References

within this rcpoY"t to corrective action taken by the Committee relate

on1\' to materials and information submitted by the Committee within

thc·30 day rc~~o~sc period which ended on September 2, 1980.

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In addition, a re'licw was performed of the expenditures made

by the Committee a~d to verify the Committee's net outstanding

campai,~;n oblisatio:-,s as of August 31, 1980.

Apparent OVQrstatc~0nt of $6,619.83 in ending cash due to

various arithm0tical errors in rCIJortcd receipts activity .
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A. Findings Relating To Title 2 of The-United States Code

1. Limitations On contributions

Section 44la(a) (1) (A) states that no person shall

make contributions to any candidate or his authorized political

committees with respect to any election for Federal office which,

in the aggregate, exceed $1,000.

During the review of the Committee's contribution

records, the Audit staff not(lU ten (10) contributors who exc0(~ded

the $1,000 contribution limilation by a total of $6,131.00.

Committee oificials believed they could provide

additional documentation to allocate the contributions to more

than one individual.

The Comnittee provided evidence that indicated that

one (1) contribution in the amount of $2,000.00 should have been

attributed to various individuals in a partnership. In addition,

the Committee stated that on l\uqust 18, 1980 letters were mailed

to each individual in Attachmcilt A requesting whether the contributor

desired a refund of the excess or that the contribution be attributed

to the contributor's spouse.

Recommendation

The Audit staff reconunen<.ls that the documentation, any amendments relating thereto and copies of refund checks (front and back)

be presented to the Audit staff when received by the committee.

Any refunds made should be reflected on the next disclosure report

filed.

2. Transfers-In anJ Earmarked Contributions

Former Section 434(b) (4) states, in relevant part,

th~t each report shall disclose the name and address of each

political committee fro~ which a transfer of funds was received,

to(Jether \-lith the Jate und ~uno\lnt.

Section l04.l7(b) (·1) 0: Title 11 o~ the Code

of Federal Regulations states, in part, that each report shall

disclose the identification of each political corr.r.\ittce from

which a transfer of fu~ds was received, together with the amounts

and dates of all trans:crs, including aggregate year to date

transfers.

Section 110.6 (e) (3) of Title 11 of the COd0

of FeJeral Regulations st~tcs, in part, that the recipient of

earmarked contributions shall disclose on his next report each

COIldtlit lhrough \.;hic~ ::';:0 cont rilJutior:s passed. '
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The Audit staff's review of the Committee's

receipt records revealed that 77 transfers-in and earmarked

contributions totaling $8,003.00 from political committees and/or

individuals were either not itemized or reported as required.

Reconunendation

The Committee filed an amendment on September 2, 1980

adequately disclosing the transfers-in and the earmarked contributions. The Audit staff therefore recommends no further action

on this matter.

B. Findings Relating To Title 26 of The United States Code

1. Undocumented Expenditures

Section 9038.2(a) (2) of Title 11 of the Code of

Federal Regulations requires the candidate to repay any amounts

determined to have been used for payments of other than qualified

campaign expenses. Section 9033.1(a) (1) sets forth the documentation necessary to determine a qualified campaign expense as a

receipted bill which is from the payee and states the particulars

of the expenditure; or in the absence of such receipted bill a

cancelled check negotiated by the payee plus one of the

following documents generated by the payee which states the

particulars of the expenditure; a bill, invoice, voucher or

contemporaneous memorandum. Where these documents are not

available, then the Commission will accept a voucher or contemporaneous memorandum from the candidate or committee. The

Commission will accept a cancelled check stating the particulars

of the expenditure, or the Commission may accept a cancelled

check and collutera1 evidence to document the qualified campaign

expenses.

The Audit staff identified 94 disbursements

totaling $172,260.33 which were made by Committee check, wire

transfer or cashier's check and not adequwte1y documented as to

the particulars of the expenditures or verifiable as to representing qualified campaign expenses. The 0:,penditures were made

for purposes such as the following:

a. Payments apparently made per contract:

14 totaling $89,846.8S

b. Advances and travel reimbursements:

22 totaling $21,373.07.

c. Apparent salary or casual labor:

10 totaling $3,986.68 .

• d. Other services:

3 totaling $19,677.32.
State accounl expenses - Iowa:

33 totaling $~h,050.53•

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e.

State account expenses -:New Hampshire:

12 totalinq $11,325.88.

The Committee officials believed that they could

obtain documentation for many of the expenditures noted above.

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On July 29, 1980, the Commission made a preliminary

dt~tl.~rI~lination that, absent a showing to the contrary, $172,260.33

in C;':i)(~nditurcs ue viewed as unqualified campaign expenses and

the vdluc rep~id in full to the u.s. Treasury. The Conunittee

submi l Led doc llmt.' II ta tion for a portion of thl~ c:-:pendi tures during

the 30 day re~~ponsc period. A review of thi~; informalion revealed

that i1uequatc documentation was not submil:l('d for the following

expenditures (~;l'l~ Attachment B): a) PaymenL~.i apparently made

per contract: 3 totaling $11,32=).02; b) Advances and travel

reimbursements: 12 totaling $8,763.66; c) Apparent salary or casual

labor: 2 totalinq $2,401.00; d) Other services: 1 totaling $9,229.55;

e) 5tLl::e Account c:-:penses - 10·.·.. <1: 15 total ing $ 7 , 821. 59; f ) State

account expenses - New Hampshire: 10 totaling $10,525.88 for a

total of all categories of $50,066.70.

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1'1:0 Audit st.:lff recommenG~'~ th.:lt the Conunittee be afforded 30

days from receipt of this repo~t to provide additional documentation. No materials will be ~cc0pted after this period at which

time the final repayment to th~ u. S. Treasury will be determined.

Furt::c ~-, it is our opinion thL.:' ~~hculd the Conmi t tC'c be unable to

provide t.he required document~tion, the un<.1ocumented expenditures

should D~ vic~":cd as unqualifi<'~tl c3~.paign expenses and the value

be rL):,.:lid in full to the t]. S. Trt"').:lsury.

Hec0I1nnend0d repayment amo',lnl - item B.l - $50,066.70.

2. Det.ermination O~ ~,;t"\t. Outst311\.1inq C.:trnpai<;:tn

Obligations

Sec t ion 90 34 . 5 (I)) 0:- '1' i tIc 11, Code 0 f Fede r a 1

Rl')IJulations r04uires that thQ cdndidate submit a Statement of

~:t.~ Ou:.st.:u1din'"j Campaign Ob 1 i (~ d .i O~1~ (NOCO) vlh ich contains,

arr.onl

] other items, the tot-al 0: .:111 outstanding obligations for

q~ali =- icd cam~... ai<Jn C:·:pl~nseS ilIl': an estimate of nccc~ssary winding

do'.·:n C()~it~~ \oJit:1in 15 day~ o~ t:l\' candidate's Oi1tl\ of ineligibility.

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The Committee: i lod a Statemt.~nt of Net Outstanding

C,-1::~I::iiJn Oblic..:.Jtions on i\pril 11, 1980. On July 29, 1980, the

C0::1:::i;::~ion apr)roved the Audi~ st.J.::'~) recommendation that the

COl:".r.1it:.cc's net o~tst~ndil1\..1 c.s:':!',1i".:n obligations ~s of :-larch 27,

1030 \':':-lS $6,73.1.2, (dcfi cit). -};' In addition, there \oJerc several

C.:1Lc r Jo::ies of u:1\9L')!:ifico \.lcbl:: 0:1 the Com.mittec's NOCO statement .

T:"'.t' Ja.te 0:' :·1:n-c:1 27, l()~,! i ~~ the date determined by the

C(.,n:!:~issif)r:. ~() bc: t:h..') J~l:'" n:' int.. ·li<Jibilit,/ [or pu::-poscs

o :.. i n L U r r i : \.i (ill. 1 1 i :- i ~", ,! c. ;:': ~: ::1 e :-:pens e s •
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... As a result of audit work performed after the 30 day response period

to the interim audit report, the Audit staff determined that as of

fi/30/80 the Committee was not entitled to any futhcr matching funds

based on net outstanding campaign obligations.

DOLE FOR PRESIDENT CO~MITTEE, INC.

STATEMENT OF NET OUTSTANDING CAMPAIGN OBLIGATIONS

MARCH 27, 1980

l\ssets

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C~sh-on-hand and in banks

Accounts receivable

Total Assets

Obliqations

Accounts payable und winding

do\·;n costs

Total Obligations

$ 34, 6~9. 73

54,795. 24

$ 89,454.97

($149,845.87)

($149,845.87)

$89,454.97

($149,845.87) 5/

~0t Outstanding Campaign Obligations -

(Dc~ici t) ($ 60,390.90)

Therefore, ~s of 3/27/80, the candidate was entitled to a

m3xi~um of $60,390.90 in matching funds, reduced bv the amount

0:- r"'l~~ 1. VC1 tc contri butions recc:i v('d :1 f tcr his da te of ine 1 i r.; i biIi t':· •

Sho~n below is a recapitulation of private contributions

~nd m.:ltchinq funds received or due the Committee for the ~eriod

3/28/80 throuqh 6/30/80 the date, in our opinion, on which all

deb s \·:e r e e f f 0C t i ve 1y elimin.:l ted (j. e., f 1.1 nds \ve reav a i 1ab 1 e

to ~:1C Committee to extinquish such debts).

Ap~lication of Private Contributions, Matchinq Funds &

Joi~t Fundraisinq Receipts March 28, 1980 throuqh June 30, 1980

Pri~3te Contributions (3/28-5/21/80)

M~tc~in0 Fund Receipts (5/21/80)

Re~aining entitlement as of 5/21/80

Priv3tc Contributions (5/22-6/30/80)

Joint Fundraisinq Receipts as of 6/30/80:

$ 14,123.13

23,910.91 (S--I2",-- 3-5-6. 8 b)

$ 6,505.00

• 1~20 Cnited Rcnublic3n Commi ttt"t~ 12,490.51 6/

19SQ. RCDUblic~ln Presidenti..ll tTni t': Commi ttee

(net ~roc00Js as of 6/30/80=S26~,028.30 x 4.5~ u:) to rcm.'1ininq entitlf\r.~ent) 3,361. 3S 7/ 8,'
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Fxcluded from this amount ar0 reimbur~ment requests from three

(3) individuals totaling $731.82 and invoices from two (2)

vendors totaling $2,376.32 all of which arc disputed by the

Committee. The Committee stated that they feel that services

were not rendered and therefore do not intend to make payment.

In addition, this total is ba~ed on a Settlement of nebt filed

with the Commission on Julv 10, 1980 between the Committee

and two (2) of their vendo~s. This Sett1em0nt of Debt is

subject to the Commission's approval.

The ioint fundraising dinner was held on ~une 16, 1980. The

net procoods Here disbursed on ]\uq~t 1, lC)80 and received hy

the Commi ll("'L' on August 6, 1980. Tt is our opinion that

manit's h<,C;lIr1C available to payoff debts on or before 6/30/8()

since thl~ joint fundr~isin<J committee is an lluthorized cOn1."nittce

of the c~ndid~tc.

The joint fundraisinq dinners sponsored by this committee

we r e he 1.don \.1 u n e 1 3, 20 II nc1 27, 1 q 8 () . Fo r pu r pos e s 0 f

calculating remaininq entitlement, it is our opininn that

monies became av~ilablc to pav off debts on or hefore 6/30/80

for the Candid~te's pro rata portion of the reported net

proceeds collected by th0 joint fundraisina committee as of

6/30/80 since the joint func1r3isina comrni~tec is an authori7.cd

committee of the candidate .

'1'h('I joint fu;;dr:-tisina acrr~ement pertClinin/i to thp 1980

Rcpublic.::ln Prosidl.")nli~l Oni tv Comrni tt(·c stipu13t(·~-; that funds

wi 1.1 be disl::urspd only to the extent necess.J.ry to satisfy

outstandi ncr c1t"'bts 0 f thL' part.i cip.:l tinn c.::l:1dida.tes. HO\-lever,

the actual di~trihulion of tho not proceeds is not determinllhl0 at thir; ::im(~. ".s of C)/30,'80, the 198() ne~ublic~n

Presidenti;11 t'~1i t·~· ('nr:;;n~ ~:loe h~lS not mal1c' .:lny distrihution.

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Re-C('r.1monc1a tion

Since the Co:;.~"ittt_·'!'s 3~::('Its \·.'("'r(~ suffici·~nt to c:·:tinquish

aJ 1. debts as of aU!~O 3(), 19B(), it is tht.~ reco::-~<?ndation of the

.7\u d itst II f f t }; :1 t t :: L' C0 ~m itt <:: t.'" i s not en tit1edt0 any f tlr ther

ml 1 t c h j n Cf fund s ( S t~ .~ 11 c. F • ? ') f) 3·1 • 1 (1"') ) •
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Section 9038(b) (2) (~) of ~itle 26 of the United

States Code st3tCS, in part, that th0 c~ndidate shall pay to

the Sccretarv of the Treasurv an amount equal to the amount

f'xpcnded fro~ the matchinq p3yment account which was used for

till': DllrnQSe ether than to dc[rav qualified campaian e:-:~r'nses

elisa S~(\ 11 C.P.R. 903H.7{a) (2) (i». .

St-,ction flO 37. (9) (A) & (B) of 'T1itle 26 of the tTnited

States Code define"' the tprrn "gualific(l campaign expf'nse" to

mean "a purchas(\, p,.ym0J) t, distribution, ~an, advance, dcposi t,

or qift of mOlll'y ())- of dfl'/t"hina of value incurred hy a candidate,

or by hi s authorj :':0c1 comrni t tee, in connection with his campaian

for n(J~iinl1ti0n for elect-inn, and neither th0 incurrinq- nor oaymen t 0 f whi eh constitu tf'~: a viola tion of an~: law of the Pni ted

St.• tos or of thL"' State i 11 which the c:-:penso· is incurred or paid. II

The Audit staff's review of the vendor files

revpalcd a payment of $fl,112.03 to tr:e Virqinia nepart~c:1t of

Tax:ltion on February 29, lQ80. ~h0 purpose of the expenditure,

ass tatc c1 0 nthe copy 0 f the c h e c k , \Vas"'." i r gini a ,oJ i t h h 0 1d i nq

t .]:":, p] 11 sint ere s t <J. n d p t.~ n.:l I t'l." 0 u r- rev i 0 \.; 0 f CO!! i e s 0 f Form

\':\-5, r~:)loyer' s Poturn of Vi rqinia Income "Pax tvith!1C'ld, attachect

to t 1'..0 chec}~ co;~y rC\yc3] cd t ha t s ta te ta:-:cs had app:t r~':1 t 1Y not

beCln t,·:i thh(~ lc1 on Commi ttCf' ~~oll.]rics for the period l\p:r- i 1 through

Dcccf.'1.::·~;:, 1979. * Due to th,· 1,'ltc fili~1G 0: t.vithholdi na taxes,

tho ~u::-::-::ittec pCl.id Sl,llS.q'/ in pe:131:.:-· to t~0 Stat0 of \"irginia.

T:1t' r e::--:. (-1 i ndcr of the chect: ,11'1' 'tIn t, S , 1 C) r-;, () (5, rcprcs(~:;tl:c1 taxes

\'\i'hich sh0uld ha\"c b~;on withhl'ld avo: t:"h: l't~riod uno i:1t(~~·l\St.

to; 0 f c '.~ 1 t h ~l t t! It. . a ~l S l"\ S ;::' (' to: pen 1 t yin the

ZlP10Unt 0:= ~1,115.97 t..:.:l~; dtlt, II' the ("('~.~;itt(le's non-co:n~:::-lj"nce

\V i Lh .3 :. 0 1a \.." 3 nc1 Y: Ll S not i!l ,.. t1 r 1-('(: i :: the normal cot1 r S 0 0 f a

c,lndi ....~.Jt-·ls c.Jm~..,<'iqn for- n('ll1i:~,lti()n [i'~· olC'ction. "leo tht·reforc

h('l ic\"o th,l t this e:-:; nnd i turl\ \'::15 not :1 C!tLll i fiC'd C,lm;:'1 i(!:-\

0n ~1ul"/ 29, }()80, th~ rc~mission madt.: Cl p~-climinary

d,·t:L)r:-:-,:":-.ltinn th.:1t 0:,::_,0!1(1 i I \lrt'S mL1d(~ f01· !H:nalti0s duo from

1I( )n-cr:~~~ 1 j .. nee \\' i t h t:.1 :.: J d\'::: h,"" v i0T..:r>(~ as u r;~ ',-1:11i f i eel a ~d the

v:IIUt' !:"c:>-~id in fuJI to lh(' l'. S. 'Pro::?;ur':".

'i':... ~:: rn:nmittl'(\ he:': not t)~~t·,1:~lis~:.:;d :1n CSC~-OT••: accou:-:t for

d .._': '__ :-' its of \-:i t:~:-"r}1~1in(l t:lXCS •
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Brlsed on the items listed in B.l and B.3 above, the ]\udit st~ff

rpcomulf'nds that. the Committee repay to the r.s. rrreasury ~51,182.~7

within <)0 days of receipt of this report or provide additional

d ocum, '1\ t uti 0 n \oJ i t hinthe firs t 3 0 day s a f ter r e ce i p t 0 f t hi R r e:: 0 r t

which d0monstrates that the items are not suh;ect to r0naym0nt. 7\

rccapi Lulation of the components of the repayment amount appear belo~..::

Undocumented Fxpenses - item B.l

Apparent Unaualified Expenses item B.3

Total Repayment

S50,066.70

1,ll5.Q;

S51 , -1 R2 • f-, -; --- - ------

c. Matters Peferred to the Office of General Cnunsel -------- --------

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Certain other matters noted durina the audit were referrec

to thf' Commissicn' s Office of General Couns~l for consideration on

May 21, 1980 and Scptcmher 9,lqRO.
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FEDERAL ELECTION COMMISSION

WASHINGTON. 0 C. 20463

March 9, 1981

MEMORANDUM

TO:

FROM:

SUBJECT:

FRED EILAND

PRESS OFFICE

BOB COSTA

PUBLIC ISSUANCE OF ADDENDUM

TO FINAL AUDIT REPORT-THE DOLE

FOR PRESIDENT COMMITTEE, INC.

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Attached please find a memorandum from the Audit Division

to the Commissioners which will serve as an addendum to the

final audit report of The Dole For President Committee, Inc •

This above mentioned document was received by the

Committee and all involved parties and may be released to

the public as of today, March 9, 1981 .

Attachment as stated

cc: FEC Library

!,AD

v'Public Record
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MEMORANDUM

TO:

THROUGH:

FRO~l :

SUBJECT:

FEDERAL ELECTION COMMISSION

WASHINCTON, 0 C 20463

March 4, 1981

THE COMMISSIONERS

B. ALLEN CLUTTER, III

STAFF DIREC~~~ I

BOB COSTA

RESPONSE TO THE FINAL AUDIT REPORTTHE DOLE FOR PRESIDENT COMMITTEE, INC.

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I. Summary of Issue and Recommendation

On January 14, and February 5, 1981, the Audit Division

received from the Dole For President Committee, Inc., ("the

Committee"), expenditure information in response to the final

audit report. During the time since the close of the 30 day

response period to the interim audit report, acceptable

supporting documentation has been presented which reduces the

amount repayable to the U.S. Treasury from $51,182.67 (as cited

in the final audit report) to $3,369.44. The Audit staff

recornnends that the Commission approve this revised repayment

amount.

Further, it is recommended that this document be placed on

the public record as an addendum to the pUblicly released final

audit report.

II. Background

On Deacmber 15, 1980, the Committee received a copy of the

final audit report. The report afforded the Committee 30 da;s

to respond to certain findings and conclusions contained thcrein.~

Finding II.A.1. on page 3 of the final audit report containeq

a reco~rnendation that the Committee provide documentation relating

to nine (9) contributors who apparently exceeded the contribution

limita1;.ion. During the period following the 30 day response to

the interim audit report, the Committee provided evidence of eith~

refund, or reattribution to a fumily member for all contributors

noted. Therefore, no further action is recommended.

* On ~arch 3, 1981, the Commission determined that the expendi1

information sub~itted on Febru~ry 5, 1981 (after the close Ol

the 30 day rCSpO!lSC period) would be considered in arriving I

at the: final rt:pu·/:TIcnt amount.
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.it;

MEMORANDUM TO THE COMMISSIONERS

Page 2

Two (2) findings contained recommendations that the Committee

repay a portion of the Federal funds that it received during the

primary election campaign:

Finding II.B.3. on page 8 of the final audit report entitled

"Apparent Unqualified Campaign Expense" concluded that the Comr:littee

made a payment of a tax penalty in the amount of $1,115.97 which was;

due to the Committee's non~compliance with State law. On November

6, 1980, the Commission made a determination that the amount

($1,115.97) of this expenditure was repayable to the u.S. Treasury

pursuant to 26 U.S.C. 9038(b) (2). In its response, the Committee

stated that it would not challenge the Commission's determination

and would make a repayment in the amount specified.

Finding II.B.l. on pages 4 and 5 of the final audit report

entitled "Undocumented Expenditures" stated that the Committee made

expenditures, totaling $50,066.70, for which it did not retain the

requisite supporting documentation to show that the expenditures

were qualified campaign expenses under 11 C.F.R. 9033.l(a) (1).

During the time from the end of the 30 day response period to I

the interim report, to and including February 5, 1981, the Com~ittee

submitted information/documentation relating to the expenditures

mentioned above.

Specifically, the Committee provided cancelled checks, invoices

vouchers, and receipts to document $47,813.23 of the expenditures

noted in Finding II.B.l. of the final audit report •

Therefore, in the opinion of the Audit staff, the anount

($51,182.67) cited in the final audit report as repayable to the

U.S. Treasury should be reduced to $3,369.44.

III. Support for the Recommendation

Based on the Audit staff's review of the material submitted

by the Committee, it is recommended that the Commission determine

that the revised amount is repayable to the U.s. Treasury within

20 days of the Committee's receipt of this report.

IV. Staff Coordination

A copy of this memorandum was furnished to the Office of

General Counsel for their consideration.
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