Part of a series about the funding behind politically active tax-exempt organizations that don’t disclose their donors. You can read the other stories in the series here.

There’s little doubt that American Commitment is an aggressive advocate for Republican interests and candidates. Last year it told the Federal Election Commission it spent just under $2 million on ads in four races — the presidential, and Senate contests in Ohio, Virginia and Arizona. A quick check of YouTube shows the group spent millions more on ads that didn’t have to be reported, because of when they ran and the words they used. (“Tell Tammy Baldwin to stop putting special interests ahead of Wisconsin,” rather than, “Don’t elect Tammy Baldwin,” for instance.)

American Commitment is also a nonprofit 501(c)(4) “social welfare” organization under the tax code. Information about such groups is scarce by definition. They don’t have to disclose their donors, unlike almost any other type of organization that advocates for or against candidates.

But American Commitment’s history and funding are especially murky. Other groups with its name — but different IRS identification numbers — have appeared and disappeared. And millions of dollars designated for one or another of the groups operating under the name American Commitment seem to have vanished.

A tangled tale

Sometime in late 2009 or early 2010, a 501(c)(4) group called TC4 Trust — about which OpenSecrets.org wrote several months ago — gave $3.8 million to another 501(c)(4) with a Phoenix address. The recipient’s name, however, is smudged on TC4’s IRS form 990, where it had to report any grants that it made to other organizations.

But there’s a clue: TC4 made another $5.5 million grant the following year to a group called American Commitment — which had the same IRS-assigned employer identification number (EIN) as the unknown recipient of the $3.8 million grant the year before.

Between August 2009 and June 2011, then, TC4 gave more than $9 million to this group.

The hitch? No 501(c) organization (or 527 group) with that EIN has ever filed a tax form 990, according to IRS data. Even given the delayed filing deadlines that allow these nonprofits to send their forms in long after their activity has occurred, the American Commitment group on the receiving end of TC4’s largesse would have reported many months ago.

Fast forward to the American Commitment that was active in the 2012 elections. This group claimed — upon filing its first and only 990 to date, in November 2012 — that it wasn’t formed until 2011, meaning it couldn’t have received contributions in 2009 or 2010. Coincidentally or not, it, too, was started in Arizona, like the more mysterious group of the same name. This American Commitment reported receiving just $216,500 in revenues in 2011, the year covered by the 990, and it lists an EIN that is clearly different from the one attached to the earlier American Commitment that appeared in the TC4 Trust filings.

Are there two organizations with the same name? Apparently not: A search of IRS data listing all 990s filed over the last several years reveals only one American Commitment — the one with the EIN reported by the group active in the recent elections.

To add to the puzzle, there briefly was a third American Commitment, in addition to the mystery group from the TC4 filings and American Commitment itself. This third organization also had an Arizona link: It was started, like the current American Commitment, by Sean Noble, an Arizona-based Republican operative. Noble runs the Center to Protect Patient Rights — a “shadow money mailbox” in Phoenix whose existence OpenSecrets.org first reported in 2012.

According to Virginia business records and IRS filings, this third group soon changed its name to Free Enterprise America. In its first 990, FEA stated that it was “initially called American Commitment,” but it had “no activity in 2010 no revenues or expenses and no return was therefore filed.”

Jason Torchinsky at HoltzmanVogelJosefiak declined an interview, saying we would have to talk with the firm’s clients individually.





Noble’s pursuits Sean Noble, who has kept many of these plates spinning — having founded CPPR, Free Enterprise America, and the currently active American Commitment — has been paid handsomely for his efforts, according to the 990s filed by the groups. He hasn’t taken a salary from any of them, despite the fact that he spends 40 hours per week running CPPR, according to that group’s 990s. The other organizations report that he spends between one and five hours weekly with them. But his two companies, DC London and Noble and Associates, have been paid between $190,000 and $2.6 million annually over three years, the 990s show. Most of the money has come from CPPR, which wrote checks totaling more than $3.6 million over the course of 2009, 2010 and 2011; on top of that, DC London was reimbursed for $3.2 million in expenses. Free Enterprise America paid DC London $397,000 in 2011. In all, Noble’s firms have made more than $4 million from the groups. The number may have grown much larger in 2012, but the groups’ 990s for last year likely won’t be filed until November 2013. And Noble, who has more than 10,500 followers on Twitter, received income from at least one other 501(c)(4) in 2012: His DC London made several ads for American Action Network, for instance, a group headed by former Minnesota GOP Sen. Norm Coleman that in 2010 gave Noble’s CPPR a grant of $200,000. Money seems plentiful in this labyrinth of groups working in support of conservative causes, none of them disclosing their donors. But somehow, more than $11 million appears to have slipped away.



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