Here is the General Counsel’s recommendation in “Unknown in South Dakota.” More information here. Thanks to a reader for the pointer, a reader who also notes that the FEC General Counsel concluded in another matter that the head of a 501(c)(3) did not violate federal election law by endorsing a candidate for federal office and soliciting funds on the candidate’s behalf. It did not reach the Internal Revenue Code questions. Note: An earlier version of this paragraph mistakenly stated that the FEC ruled on IRC questions.