Political Charity Outside the Lines, Part 2

The Curious Case of the Vanishing Non-Profit

In this episode of Political Charity: Outside the Lines, we consider the case of Impact Minnesota, a 501(c)(4) non-profit, social welfare charity that arose with some fanfare in late summer 2010, only to vanish with little trace a few months later.

According to the Minnesota Secretary of State’s office, Impact Minnesota was incorporated as a non-profit on August 4, 2010. The SOS reports that the non-profit reserved the name “Base Build” on August 9, 2010. The SOS lists the company as “inactive” by “involuntary dissolution” as of August 6, 2012.

On January 31, 2011, Impact Minnesota’s 527 “Political Fund” filed its 2010 Year-End Report with the state’s Campaign Finance and Public Disclosure Board. The 527 reported that all of its spending supported Democrat Mark Dayton in his campaign for governor of Minnesota.

The Impact Minnesota Political Fund listed as its sole contributor the Impact Minnesota 501(c)(4), with $190,951.70 of in-kind contributions. (See 2010 Year-End Report, Schedule A1-UA). The Political Fund showed a year-end cash balance of zero. The majority of the Political Fund’s spending was for “payroll.”

The Impact Minnesota Political Fund showed no activity in its 2011 or 2012 filings and is listed by the Board as “terminated” as of September 25, 2012.

Strangely, neither Impact Minnesota nor its 2010 IRS Form 990 income tax return can be found on GuideStar, the non-profit corporate financial information service. Without viewing the tax return, we cannot determine whether Impact Minnesota’s political donations represent the primary activity of the non-profit.

The non-profit’s website, www.impactminnesota.org, no longer exists. The URL is no longer owned by anyone and is available for purchase. Viewing the old website in Archive.org’s Wayback Machine, the old website claimed that “Impact Minnesota is a 501 C4 Non-Profit Organization.”

The Political Fund’s 2010 Year-End Report was signed by Mike Misterek, who now serves as Congressman Rick Nolan’s chief of staff. Certifications for the Political Fund were signed by Corey Day, who now serves as the Executive Director for Minnesota’s Democrat Party (or DFL, Democrat-Farmer-Labor as we style it in Minnesota).

Indeed, the organization seems to have been run by Mr. Day, whose firm Strategic Field Concepts, was a vendor to the 501(c)(4)/Political Fund, receiving payments totaling $20,850 for “payroll.”
A September 2010 article in MinnPost,[1] describes Mr. Day’s formation of the organization,

IMPACT Minnesota, a new independent-expenditure political action committee, has formed to focus on getting out the vote in the African-American community and in letting candidates know the impact black voters can have on the outcome of elections.

It will also be there to help DFL gubernatorial candidate Mark Dayton.

IMPACT Minnesota’s executive director is Corey Day, who is also a partner in the St. Paul-based political and social media consulting firm Strategic Field Concepts.

It may be worth noting again that the Political Fund received 100 percent of its funding from the related non-profit entity. As Mr. Day explained to MinnPost,

“At the end of the day, our focus will be getting folks out for Mark Dayton.”

Alas, Mr. Day’s long-term hope for the organization didn’t pan out. MinnPost reported in September 2010,

Still, Day said that IMPACT Minnesota will have a life beyond this 2010 political campaign. “We are not the kind of organization that packs up the day after an election,” he said.

Mr. Day sheds some further light on the organization in this September 18, 2010 YouTube interview with Don Allen. This on-line bio for Mr. Day includes the following details,

Partner at Strategic Field Concepts. Executive director of IMPACT Minnesota, an independent expenditure PAC focused on the African American vote, Fall 2010.

Curiously, Mr. Day’s brief stint at Impact Minnesota is missing from his official state Democrat Party bio.

What should we make of this fly-by-night operation? If I were a real reporter, I would have these questions for Messrs. Day and Misterek:

  • Did Impact Minnesota file for an EIN (Employer Identification Number, the corporate equivalent of an individual’s Social Security number)? If not, why not?
  • Did Impact Minnesota apply for 501(c)(4) status? If not, why not?
  • If so, did Impact Minnesota receive 501(c)(4) status? If not, why not?
  • Has Impact Minnesota filed a 2010 federal income tax return? If not, why not?
  • How much of Impact Minnesota’s non-profit operations were represented by its political contributions?
  • Did Impact Minnesota have employees? If not, why not?
  • If so, did Impact Minnesota deduct payroll and income taxes from its employees? If not, why not?
  • If so, did Impact Minnesota submit these deducted monies to the state and federal treasuries? If not, why not?

We will have more to say about Impact Minnesota in upcoming posts.

Cross-posted and comments welcome at BillGlahn.com