The fact pattern in the Trump and Edwards cases is different, but the basic principle is the same. I found this brief in the Edwards case from CREW on how the government’s interpretation of the law would perversely and against the clear intent of the law transform personal expenses into campaign expenses very helpful.


Also, it’s pretty clear that the FEC views “the irrespective of the campaign” standard as a bright-line test rather a subjective question (i.e., the expense was 55 percent campaign-related and 45 percent personal, therefore it should be considered campaign expense). From the Federal Register: