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FEDERAL ELECTION COMMISSION

.. WASHINGTON. D.C. 204&3'

REPORT OF THE AUDIT DIVISION

ON THE

IDAHO STATE DEMOCRATIC CENTRAL COMMITTEE

I. Background

. A. . Overview .

'This report is based~on an audit of the Idaho

State Democratic Central Coml"Rittee ("the Committee"),

'., : undertaken by the Audi t Division of the Federal Election

Commission in accordance ",oli th the Commission's audit policy

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 438(a) (8) of Title 2 of the United States Code

.which directs the Commission to make from time to time audits . 3nd field investigations with respect to reports and statements . f 11eci,'O u.n,CieJ;the provisions. of.... the i\ct .•.

The Committee registered with the United States General

Accounting Office as the Idaho State Democratic Central Committee

on September 11, 1972, in support of Federal and State candidates.

In a letter dated December 16, 1977, the Committee notified the

Commission that all cash on hand as of October 1, 1977, would be

allocated to its state accounts for state and local purposes only.

The Committee filed its year-end report for 1977 ..on February. 7',

'1978, which reflected this allocation.'" On February 7, 1978 ~the . Committee registered with the Commission a.separate Federal

account, the Idaho State Democratic Committee. The Committee

maintains its headauarters in Boise, Idaho. • '> • • ,

The audit covered the period from January 1, 1976

through December 31, 1977~. the final coverage date of the last r-'~~ort :iled by the Committee ;?rior to its registration amendment

for Federal purposes only.

The Idaho. State Democratic Central Committee reported

a beginning cash balance on January 1, 1976 of $4,799.97, total

receipts of $131,963.81, total expenditures .of $136,763.78,

and a closing cash balance on December 31, 1977 of $-0-. The

separate Federal account remained inactive from date of re~istration through audit fieldwork.
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This aUdit report is based on documents and working

paper~ which support each of the factual statements. They

form part of the record upon which the Commission based its

deci~> Lons on the matters in the report and were available

to Commissioners and appropriate staff for review.

B. Key Personnel

The principal officers of the Committee during.the

period audited were: Mr. Deckie Rice, Chairperson from

Januarv 1, 1976 to March, 1977; and John Greenfield, Clhlirperson

from J~ne, 1977 to'December 31, 1977; and .John Chapman, Treasurer,: ..

from January 1, 1976 to June 1976: and Paul J. Buser, Treasurer

from June 1976 to December 31, 1977. 1/

C. Scope

The audit included' such tests as verfication of

reported receipts and expenditures and individual transactions:

review of required supporting doc~~entation and analysis of

Committee debts and obligations: and such other· audit· procedures

as deemed necessary under the circumstances.

D. Discussion

The Idaho State Democratic Central Committee, for the

period covered by the audit, operated as a committee supporting

Federal and non-Federal candidates. Both state and Federal

activity was included in the Committee's reports filed with t~e

Commission. We noted two (2) accounts which were used to'fund

the Committee's Federal activity which ceased on August 4, 1976:

the "Operating" account and the "Tax Check-of::: Savings" accot:nt.

~1.6~ of the :::unds deposited into the operating account were

tr~nsfered :::rcm two (2) other state accounts.

Contributions deposited into these :::our (~) accounts

were not desig~ated for Federal activity. F~rther, although

the Committee received corporate and labor organi~ation

contributions durinq the oeriod Februarv 26, 1976 to June 28, 1977,;

none were deposited~into any of the acc~u~t~ c~nnected with'

Federal acti"litj. We also noted that ~4 transfers from unregistered

1/ The Co~~ittee had a vacancy in the Office of Chairperson

for the period ~arch to June, 1977. Thi3 is ~ot considered

:na terial si~ce the Committee ',vas not encrac:ed in an:: Feder 3.1

acti'li t~, during this period. - -
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subordinate county committees and state candidate committees

were accepted by the Committee totaling $5,106.10. Of this

total, only one (1) transfer from a state candidate committee

for $48.66 was directly deposited into the Operating account

prior to the only Federal activity from that account on July 9,

1976. In addition, although some of these transfers were

accepted into the two (2) other state accounts during the

period that transfers were being made to the Operating account

up to August 4, 1976, none aggregated in excess of $1,000 from

a single committee, and these unregistered committee-transfers

comprised an insignificant percentage of total funds received

into the two (2) other state accounts.

~r We recommended in our interim audit report that the

Committee amend its reports for the audit period to reflect

only the activity in the accounts involving Federal activity,

modified by t~o fin~ings affecting those accounts.

On August 21, 1979, the Committoe amended the coverage

dates of their te~ination report to ref18ct an August 4, 1976

closing, t~e date of the Committee's fin~l Federal activity. T~e

amended report contained information requested in the interim

audit ~eport for those four (4) accounts involving Federal

activi~y for the period up to August 4, l~76, and a statement that

the Ccmmictee no longer engaged in Feder31 -activity subsequent to

that date. The Committee also stated tl'lat as of August 4, 1976,

all remaining cash on hand was used for state and local purposes

and taat all debts and obliqations owed to or bv the Committee as

of August 4, 1976 ~elated so181y to non-Federal· activity. -

In the opinion of the Audit staff, the Committee's

amended ~e~~ination report adequately responds to our interim

audit reoort because it amends the Committee's reports to reflect

only accounts related to its Federal activity, through the amended

termination date.

II. Descri?tion of Findings

A. Apoarent Excessive Contribution ~nd

Reporting of In-Kind Contribution

Section 44Ia(a) (1) (Cl of Title 2, United States Code

st3tes no person shall make contributions to the political

co~mittees of state ~olitical parties in any calendar year

which, in the ~ggregate, exceed $5,000.
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Section 434(b) (8) of-Title 2, United States Code,

requires each committee to include in its disclosure reports

filed with the Commission the total sum of all receipts by

such committee during the reporting period. Section 104.3(a)

requires each in-kind contribution to be valued at the usual

and normal charge on the date received and reported if in excess

of $100 on the appropriate schedule of receipts, identified as

to its nature and listed as an "in-kind contribution": and to be

so identi£i~d on the appropriate expenditure schedule at the same

usual and normal charge.

During the audit we noted a contribution was accepted

on August 23, 1976 by the Committee in the amount of $5,800

from an individual. This represented an in-kind contribution

in the form at: a gift of a document processing machine which

the Committee has since disposed of. When questioned, the

Committee's former Executive Director stated that at the

time of acceptance the Co~mittee was unaware of the 55,000

limitation and that the value of the contribution was established by the donor of the machine. The contribution was itemized

on Schedule A by the Committee, identified as an in-kind

contribution, but the amount was not included ±n reported

receipt totals. .

Recommendation

On July 17, 1979, the Committee filed an affidavit from

the donor setting forth a revised value of the machine

at the time of the contribution of 54,500. Since the Committee's

acceptance ot the machine cccur~ed after August ~, 1976, when

the Co~~itte~ no longer was engaged in Federal activity, we

recommend no fur~her action on t~is m~tter.

B. Itemization of Exnenditures . Section 434(b) (9) of Title :!, United States Code requires

committees to include in thei= ~eports filed with the Commission

the identi~ic3tion of each ce~scn to whom expenditures have been

made bv such cOInmittee .within ~::e calendar year in an aggregate

amount-or value i~ excess 0: S~C0, the amount, date, and purpose

of each such ex~enditure and ~::e name and address 0:, and off~ce

sought by, each" candidate on w::cse behalf such expenditu=e was

made.
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During the course of the audit it was determined that

the·Committee made 31 expenditures from its operating account,

each aggregated in excess of $100 per payee, totaling $1,210.12,

which were not itemized as required on reports filed with the

Commission. These expenditures were made during the period of

January 27, 1976 through September 15, 1977. These omissions

represented 11.4% of the total number of expenditures requiring

itemization and 1.5% of the total dollar value.

Recommendation

The Committee's amended termination report filed August 21,

1979, included those previously unitemized expenditures which

occurred prior to August 4, 1976, during the Committee's period of

Federal actiVity. Since the Committee has satis:actorily amended

its reports for the period during which it engaged in Federal

activity, we recommend no further action on this matter.