“Each of us in our respective practices representing 501(c) organizations is all too familiar with the problems related to existing law and guidance on exempt-organization political activity. ….  Because the law itself is not clear, we often find ourselves unable to give our clients the clear answers they seek and should reasonably expect.”

21 prominent tax-exempt attorneys with clients across the political spectrum signed on to these comments, which provide bullet point concerns and suggestions that get right to the point.  The commenters are hopeful that the IRS will view the influx of largely negative comments as workable guidance rather than as “an insurmountable barrier to a good final rule,” referring to the success of the prior rulemaking process for 501(c)(3)s on lobbying for public charities and private foundations that occurred in 1986-1990.