Following up on this post, Brett Kappel emails to explain the difference between the FEC’s treatment of the Swift Boat Veterans and Moveon.org on the one hand, and the Leadership Forum on the other:

The Leadership Forum found a way to avoid becoming a “political committee” while still raising corporate money and spending it to indirectly affect the 2004 presidential election to benefit George Bush. To avoid becoming a “political committee” the Leadership Forum raised funds in solicitations that did not use the name of any federal candidate. They then used those funds to spend over $300,000 in a partisan GOTV effort in three key states – Nevada, Colorado and New Mexico – right before trhe 2004 general election. The Leadership Forum’s GOTV effort consisted mainly of re-publication of state-produced voter information, such as the dates and locations for early voting in the three states. No federal candidates were mentioned in any of The Leadership Forum ads – only state and local candidates.
So The Leadership Forum helped turnout Republican voters for the 2004 general election, but the 527 wasn’t a political committee because unlike the Swiftboaters it never explicitly stated in its solicitations or its ads the name of a federal candidate.