Boardman writes: "Whatever you hear about tax exempt, 501(c)(4) organizations these days, someone is probably playing politics, or simply lying (for the sake of playing politics). And even if you're not hearing about it, they're still lying about it."
House Ways and Means Committee chairman Rep. Dave Camp (R-Mi). (photo: AP)
The IRS "Scandal" Goes On
26 February 14
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It's not easy to keep a "scandal" going where there's no scandal
hatever you hear about tax exempt, 501(c)(4) organizations these days, someone is probably playing politics, or simply lying (for the sake of playing politics). And even if you're not hearing about it, they're still lying about it. This is all about bi-partisan deceit designed to defend the flow of dark money from secret donors.
The focal point of the "IRS scandal" these days is a new set of regulations announced by the IRS in November and currently open for public comments, which total more than 69,000 just days before the comment period is to close, on February 27.
In case you missed it, Republicans on the House Ways and Means Committee, led by Rep. Dave Camp of Michigan, have introduced a bill that would block any new regulations, and would also, in effect, make it against the law for the administration to follow the law. That's literally true. The proposed legislation, H.R.3865, has a fictional title: "Stop Targeting of Political Beliefs by the IRS Act of 2014" and really, who could be against that?
It would be like opposing the "Stop Brainwashing of Our Children by the Dept. of Education Act of 2012," which is an imaginary response to an equally imaginary threat. Just like the IRS targeting of political beliefs. Of course Imaginary threats can be more powerful than real ones sometimes, like those WMDs in Iraq that are still imaginary and still exploding people's heads at home and abroad more than a decade after their mushroom clouds were first inhaled.
More than 5,000 applications for 501(c)(4) status swamped the IRS by 2012
Before exploring H.R.3865 further, let's recall the reality of the IRS non-scandal of 2013, which continues to be widely misreported to this day (on February 13, the New York Times falsely described the essential issue as "heightened scrutiny the IRS gave to non-profit applications from Tea Party-affiliated groups" � never mind that it didn't happen, at least not at all like that).
The Supreme Court's 2010 decision in Citizens United v. Federal Election Commission unleashed huge amounts of previously dirty money into American politics, giving a lawful competitive advantage to everyone with money to burn. Not that those people were previously disadvantaged. They already had 527 organizations to take as much money as they had to give, but the 527s had the unfortunate legal requirement of having to report publicly who gave them money, and how much. And this was unfair to rich people who are shy about revealing the politicians they buy.
Citizens United also contributed to the rush to set up 501(c)(4) non-profit vehicles, which had the enticing additional option of being able to keep its donors secret. Citizens United, the organization, is itself a 501(c)(4) with a pretty clear political/ideological bias. The case it took to the Supreme Court began when it was prevented from running a documentary hit piece against Hillary Clinton in 2008. Now Citizens United is threatening another lawsuit should the IRS try to enact new rules controlling 501(c)(4) activities.
In other words, the fake IRS "scandal" was a very real part of a much larger Supreme Court scandal. Karl Rove was one of the first in a rising tide of 501(c)(4) applications during 2010-2012. According to reports, from roughly 1750 applications each in 2009 and 2010, the total rose to 2265 in 2011 and 3357 in 2012. The IRS was swamped and casting about for ways to triage the applications and handle them more efficiently. And there's the rub. That would have been easy under the original law, the Revenue Act of 1913, as codified in the U.S. Code, in its relevant entirety:
26 U.S.C., Title 26 Ch. 1, Part 1, sec. 501(c)(4)�. [Internal Revenue Code]
(4)(A) Civic leagues or organizations not organized for profit but operated exclusively for the promotion of social welfare, or local associations of employees, the membership of which is limited to the employees of a designated person or persons in a particular municipality, and the net earnings of which are devoted exclusively to charitable, educational, or recreational purposes. [emphasis added]
(4)(B) Subparagraph (A) shall not apply to an entity unless no part of the net earnings of such entity inures to the benefit of any private shareholder or individual.
Just follow what the law says on its face � approve an entity "exclusively" for the enumerated purposes � and there's no problem at all. None. Follow the law, and NO organization with the slightest whiff of political activity is eligible. Such organizations are, by definition, excluded.
So what went wrong? In 1959, for reasons that remain obscure, the IRS decided to issue regulations that contradicted "exclusivity." The exact, fundamentally irreconcilable language the IRS adopted by regulation (the statute remained unchanged) created an impossible quandary for a regulator: "An organization is operated exclusively for the promotion of social welfare if it is primarily engaged in promoting in some way the common good and general welfare of the people of the community."
How can anyone square that circle? For some reason 501(c)(4) organizations remained non-controversial for more than fifty years. And the controversy arose only because right-wing politically-engaged Tea Party groups in large numbers were trying to take advantage of a fundamental irrationality in tax regulations. There's a kind poetry in that, as these willful, would-be tax cheaters created an inflated, politicized, made-up problem that still obscures the real problem: trying to enforce incoherent law.
In June 2013, the Inspector General for Tax Administration reported that, of the 5,000 or so relevant cases, the IRS identified 298 as "potential political cases," less than 6 per cent of all cases. And for all the accusations hurled by Tea Party groups and their allies about unfair treatment, in the end, none of their applications � not a single one � was denied 501(c)(4) status by the IRS. Further underlining the political speciousness of the right-wing lie machine, IRS rules allow 501(c)(4) status to apply to anyone who CLAIMS it, whether they've applied yet or not.
Inspector general's behavior prompts call for investigation
Yes, the IRS inspector general identified 298 "political" cases (and a few others in grey areas) out of the 5000-plus reviewed � but of those 298, the inspector general found only 96 identified by "Tea Party," "9/12," or "Patriots," but did not identify the names attached to the other 202 "political" cases, thus blurring the apparent reality that Tea Party type groups, despite the overt political nature of their names, still represented only a minority of the "political" applications reviewed. The facts seem to suggest some even-handedness by the IRS, whatever tactical clumsiness it may have had in engaging a standard that had no reliable meaning.
The suspicious sloppiness of the inspector general's report, which fed the paranoid fantasies of the unpersecuted right, has contributed to a recently-filed ethics complaint against the inspector general himself. On February 5, two House Democrats � Gerry Connolly of Virginia and Matt Cartwright of Pennsylvania � filed a 22-page complaint prompted by the inspector general's having briefed only Republicans on aspects of the Affordable Care Act, as well as the inspector general's numerous meetings with congressional staffers on Republican Rep. Darrell Issa's staff, meetings from which Democrats were excluded.
The inspector general, who is a Republican and a former Congressional staffer, was criticized for the apparent bias of his report as soon as it was released. His report also omitted the fact that his staff had reviewed thousands of IRS emails and had found no hint of political motivation for the ISR procedures. Subsequent reports have reinforced the conclusion that the IRS did nor "target" or "single out" any particular political ideology in their efforts � which ended up approving every application.
The ethics complaint filed with the Integrity Committee of the Council of the Inspectors General on Integrity and Efficiency (CIGIE) questions the inspector general's "independence, ethics, competence, and quality control." The Council, which includes members of the Office of Management and Budget and the FBI, has not announced a schedule for its investigation into the complaint.
FBI confirms lack of IRS wrongdoing. Right wing fumes.
The Wall Street Journal, reporting on January 13, continued to assert that the unproven "heightened scrutiny" was a reality:
"The Federal Bureau of Investigation doesn't plan to file criminal charges over the Internal Revenue Service's heightened scrutiny of conservative groups, law-enforcement officials said, a move that likely will only intensify debate over the politically charged scandal. The officials said investigators didn't find the kind of political bias or 'enemy hunting' that would amount to a violation of criminal law. Instead, what emerged during the probe was evidence of a mismanaged bureaucracy enforcing rules about tax-exemption applications it didn't understand�."
Clearly The Wall Street Journal doesn't understand, or doesn't want to understand, that in this instance, the "rules about tax-exemption" are not merely incomprehensible, but violate the underlying law. But the Journal story goes on for most of its length editorializing about its hopes that the continuing investigation will finally turn up something against someone.
Later the same day, Fox News pushed the surreality of the right's presumption of guilt by somebody somewhere a little harder, albeit with a belated "allegedly" after treating the "scandal" as a fact:
"The FBI has so far found no evidence that would warrant the Justice Department filing criminal charges in its investigation into the IRS targeting scandal, federal officials confirm to Fox News. The findings, which were first reported by The Wall Street Journal, could intensify the debate over the scandal, in which the IRS allegedly targeted Tea Party and other conservative groups applying for non-exempt tax status for special scrutiny." [emphasis added]
Headline: "New Dark-Money Rules Won't Stop Dark Money"
Under that headline, Mother Jones responded to the proposed new IRS rules on 501(c)(4) non-profits with four reasons why they wouldn't matter much. For one, the rules don't define what "primarily" means, so there's no guideline for how much political activity is too much. Also the proposed rules apply only to 501(c)(4) non-profits, not any of the other dark money pipes � for example, the rules don't apply to 501(c)(6) non-profits, which the Koch Brothers used to distribute $250 million in dark money in 2012. And in any case, the proposed rules are only "proposed" and may never be enacted.
Mother Jones also points out that the IRS, in the midst of recent budget cuts, job cuts, and political attacks, is afraid of seeming partisan and so prefers to do as little enforcement as possible.
Mother Jones does not mention that none of their analysis cuts to the basic problem in the law: that no 501(c)(4) non-profit organization is allowed by law to do ANY political activity. There is no mention of the obvious Gordian Knot solution to the problem: scrap the rules, just enforce the law. Nobody wants that. Not Republicans, because they're awash in dark money to such an extent they hardly know where to spend it. And not Democrats, who get enough dark money to keep hope alive that someday they'll get as much as Republicans.
Adding to this bipartisan morass of meaninglessness, the Republican majority of the House Ways and Means Committee, on a straight party-line vote on February 18, approved H.R.3865 and sent it to the full House for a vote that may or may not happen. Introducing the bill a month earlier, committee chair Dave Camp began by asserting a new bogus argument in this already largely fact-free debate:
"Over the past six months, this Committee has investigated the Internal Revenue Service's targeting of conservative groups. Though our investigation is not complete, and the IRS still has many more documents to provide to the Committee, we have discovered a concerted effort by the IRS to limit the ability of those targeted conservative groups to operate and engage in constitutionally protected public debate."
Republican: First Amendment demands subsidy for rich folks' speech
When Dave Camp says "constitutionally protected public debate," he's calling on the free speech rights of the Constitution's First Amendment, and he's doing it with the purest dishonesty. There is NO free speech issue involved with 501(c)(4) organizations. People in those organizations can say whatever they want (usual restrictions apply) and suffer no penalty.
The sole relevant point of tax-exempt status is that it provides a government subsidy for the approved activities. That subsidy takes the form of reduced taxes for donors to tax-exempt organizations, a donor class dominated by the rich. It other words, it's another form of welfare for the wealthy, justified by the argument that the money is going to support the general welfare as recommended in the Constitution's preamble.
For Dave Camp and his ideological clones, rich people deserve to have their political speech subsidized by the government in order to protect their First Amendment free speech rights, while keeping their identities secret � a perfectly egalitarian position, since anyone, no matter how poor, is free to make the same donations and get the same tax benefits and secrecy. That's a patently dishonest argument the powerful have long made and too few have challenged.
In the 2012 election cycle, outside groups who reported to the Federal Election Commission spent more than $1 billion to influence the vote. About a quarter of that was 501(c)(4) spending. This sector of non-profit political spending amounted to $1 million in 2006. The total was up to $92 million in 2010 and went over $250 million in 2012 � all subsidized by a federal government that allows donors to hide their identities.
The original law covering 501(c)(4) tax-exempt organizations [see above] is really clear: to be tax-exempt, you cannot do any politics. No one in authority anywhere seems to want to enforce this law as it stands. Democrats propose ineffective new regulations to replace the ineffective old regulations, even though none of these regulations are based in the law. Republicans argue for a new law which will block any enforcement of the currently unenforceable regulations in order to have their IRS witch hunt go on distracting the credulous.
In July 2011 � almost two years before the "scandal" was manufactured � three organizations (Public Citizen, Democracy 21, and the Campaign Legal Center) and a congressman (Democrat Chris van Hollen) filed a petition with the IRS requesting that the IRS revise its 501(c)(4) regulations to conform to the law. The IRS did not start work on new regulations and did not respond substantively in any other way. In the summer of 2013, these same plaintiffs filed a complaint in U.S. District Court for the District of Columbia, asking the court to order the IRS to follow the law. In the words of the complaint:
"Defendant Internal Revenue Service (IRS) has for many years violated the Internal Revenue Code (IRC) by allowing tax-exempt social welfare organizations to expend substantial sums on electoral activity. The IRC [code] provides that tax-exempt social welfare organizations must be 'exclusively' engaged in 'promotion of social welfare.' IRC sec. 501(c)(4). The IRS' implementing regulation recognizes that electoral activity does not fall within the scope of activity promoting social welfare. Treasury Regulation (TR) sec. 1.501(c)(4)-1(a)(2)(ii). But the IRS's regulation also purports to provide that an organization operates 'exclusively' to promote social welfare as long as it is operated 'primarily' for social welfare purposes. Id. Sec. 1.501(c)(4)-1(a)(2)(i). By redefining 'exclusively' as 'primarily' in violation of the clear terms of its governing statute, the IRS permits tax-exempt social welfare organizations to engage in substantial electoral activities in contravention of the law and court orders interpreting it." [emphasis added]
In September 2013, District Judge John D. Bates granted a motion to consolidate this case with another filed on the same issue. He also denied an IRS motion to dismiss the complaints. Since then, there has been no further development on the case.
Altogether these elements comprise the dominant paradigm for American governance in the early 21st century: Republicans keep on lying. Democrats keep on shucking and jiving. Bureaucrats run for cover (except the partisan ones). The Court delays. Most of the media follow the food fight rather than the statute or the facts. And pretty much everyone everywhere ducks the essential, underlying question: Is there ANY rational argument to be made for taxpayers subsidizing any random political activity by anyone anywhere?
William M. Boardman has over 40 years experience in theatre, radio, TV, print journalism, and non-fiction, including 20 years in the Vermont judiciary. He has received honors from Writers Guild of America, Corporation for Public Broadcasting, Vermont Life magazine, and an Emmy Award nomination from the Academy of Television Arts and Sciences.
Reader Supported News is the Publication of Origin for this work. Permission to republish is freely granted with credit and a link back to Reader Supported News.
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And about Israel: I would hope that people allow that country to determine the best course of action for itself, and not pour money into campaigns that the Israelis themselves do not want. For those who point to Bible prophecy: I respect religious opinions, but consider the story of Jonah: he finally warned Ninevah, they repented, he got mad that he had spent time in the whale, and with the example of the gourd it was pointed out that sometimes forgiveness is given for repentance. Those prophecies are supposed to point to a good direction, not just give a blanket punishment, but prophecies may be self-fulfilling with the kind of meddling that Adelson is doing.
We the People just won't buy what they are selling. Let them waste their money. Don't vote republican on any level.
My post was to anybody who might give Adelson an excuse for his meddling. At one time, any foreign meddling in an American election was a serious offense; a foreign corporation could lose their licenses to do business in the United States. I wonder where those laws went?
This last year, I've been seeing loads of out-of-state license plates, all good cars. Most people change their license if they are moving here, so I assume these are all the out-of-state people coming to Ohio to pay people to vote Republican. Most people don't buy it, but all those out-of-state plates prove they are trying.
Yall benefited from the bail-out of GM I believe, so I hope many, many more Ohioans will also vote Dem. It is going to be a trying time, for since you are THE swing state, you will be bombarded with negative adds. STAY STRONG
Isn't that typical for the rich jerks. It is too bad that the people need the job, for I would LOVE to see them all march out and leave him stranded, high and dry with nobody to run his damn casino.
Of course, he does nothing for the community, People like him just take, take, take. they only give when they are certain to get what they want in return. A pox on him
I've been wondering if and how all this money that's flowing so freely is being written off. Of course when you make that much money, the IRS turns a blind eye. But if $1 of the Adelson, Koch, Rove, or other Super Pac money is being hidden or written off, we are making up the difference. Isn't that the other aspect of anonymous donations?
Not even social security will you find there and their equilivent of medicaid was gutted in the 1980's. Their master plan calls for a social security program to increase domestic consumption but it is a longer term plan,not immediate.
This Mr Adelson...Don't know him of course but I can only assume he is not really considering himself a citizen with US interests at heart but a global citizen here to use the US for all it is worth..very.sim iliar to Reupert Murdouch.
Their interest is to use the US for personal financial interest.
When the US is no longer at the top of the financial heap, his heirs by my take will then be Chinese citizens using that place for their personal gain. Similar to Reupert and his Chinese wife, really they care not about what country they are in or meddling in...their concern is all about personal profit.
The amounts of money now being donated to campaigns compared to the amounts of money at stake for guys like this is minuscule.
Keep in mind the ramifications of citizens united are just now being felt....it is just starting..
I wonder why they do not just start paying people to vote a certain way....would that not also be a exercise of free speech...since money is speech by their determination.
Your ward goes this way...1k each to each voter...why not?
Just imagine what Social Security and Medicare/Medica id could do with that money. Think of all the people it could help. And then I look at people like Cheney, Rove, Murdoch and this clown, Adelson... it puts me somewhere between rage and nausea.
"..There are no "undecided" voters any more. More crap on tv is not going to sway people one way or another."
Never over-under-esti mate the ignorance of the American public! Of course money can, will and does, buy elections, over the TV.
You may be correct that there are no undecided voters left.......in THE PRESIDENTIAL part of the election,... but
all that money can make a HUGE difference in the CONGRESSIONAL election.
I doubt the democrats will have a lot of money, and most people don't pay much attention to representatives and senators therefor if Adelson's money is used to throw a lot of dirt at the democratic candidates, it can make a BIG difference
So unless democrats really work hard for their candidates, they will have little chance of getting more Dems in the house.
This nasty SOB may be able to determine who wins this election, because of all his money.
We are certainly not a democracy any longer. He MIGHT not be able to unseat the president he hates. But his filthy money could destroy GOOD law makers.
....Contrary to belief....they DO exist.
He proves that no matter HOW much money some people have they want STILL MORE. And they want the middle class to pay the taxes, they want to avoid. He is sickening
And don't forget to volunteer to work with your local political group. You don't have to have money to get involved. And your involvement may be just the thing that turns an election around. This money is being used not only to combat President Obama, but all the way down to the local level. You can bet that Rove knows who's running in every district in the country and will bring his money to bear against any candidate he thinks is vulnerable.
The only way we can beat the money is with bodies - lots and lots of bodies.
It's men like Adelson who make the world an ugly place. If he continues, it will probably also be uninhabitable, because I guarantee to you that if the Rethugs win up and down the line, the biggest casualty will be the environment.
It could come from China!...We simply have NO idea. We do not have elections anymore. We have AUCTIONS.
And the winner is???.....The highest bidder. How sickening, and we have the NERVE to tell other countries, how to run elections and build democracy??
I meant to give you a negative not a positive vote for your foolish remark. Adelson hates America, he is a Zionist who would rather have worn the military uniform of Israel rather than the American one he wore.
I can't believe I spent some money at his Venetian Casino in Las Vegas when I was there recently.
I would hope he has a better use for 30 million dollars than to point and shame;thus throwing himself into the shame/blame game, the Republicans favorite form of lying which works well in this imbecilac country.I wish I could stop these lunatics,but my bank account isn`t big enough.
Frankly, I think there is a good chance that that may happen and that the Republican office-holders and wannabes will be swept away in a spew of voter vomit.
Billionaire (who owns a piece of everything) -
lots of ads, paid into big media -
owned by billionaires (who make profit on the ads) -
lots of ads, paid into big media - ...
They can't lose on this, and they will still have all their money in the end!
Of course that applies to the Middle East brand of Mormonism, another "M" cult absolutely devoted to denial of the divinity of Jesus of Nazareth. Masons too.. Interesting, the "Shriners" with their Islamic symbolism, swords and red fez costumes?
But the mills of prophecy grind along, with the Saudis deepening their ties with China, closer to the long feared oil for nuclear missiles transaction. Mr. Adelson would show much greater discernment were he and Mr. Winn et al able to grasp the need for American transport policy re-orientation as key element in defusing the Middle East noose around America's neck. It's about Petrodollars, stupid!
The scriptural warnings about Jerusalem as stumbling block for the nations do not necessarily include America, but as things stand, it seems likely. Adelson should read "The Blood Of The Moon" and counsel Mitt Romney on the prophetic and spiritual forces at play. America's relationship with Israel must be considered, not overplayed to bad end.
Could Jastrow's "The War And The Bagdhad Railway" scheme offer engineering solution to Palestinian resettlement and Islamic goals of regional unity, hold Israel harmless, and stifle relentless moves to cataclysm?
I think that God is intelligent, don't you?
I also always felt that's why Adelson vigorously solicited the Chinese to build casinos in their territory. He has a delusion that the Chinese government will let him take all his money there and they will protect him and his money.
I predicted years ago that Adelson would eventually take his bad ideas and his money and head for Macau to live permanently just not to pay a few percent of taxes.
Either human beings have rights or they don't. If you believe some group of humans identified by their ethnicity or religion do not have human rights, then you are in violation of the UN Convention Against Genocide and the Universal Convention on Human Rights. Such beliefs put Adelson in the company with Nazis and other avowed racist groups. I'm sure he does not give a damn.
The truth is that Israel would be a lot safer and better off with a viable and healthy Palestinian state.
I agree with Nick Neuaur (Ted Conference speaker who's speach isn't included because of what he had to say)that the middle class creates jobs because they can spend. Nick said he can buy 3 cars but the middle class can buy 3,000.
Adleson is in this for short term gain because when the middle class can't afford to gamble he's not going to make any more money.
Europe and America is:
No money in politics
No death penalty
No guns
universal healthcare
W O W what a difference that makes.
President Roosevelt in a message to Congress in 1938:
"A democratic society is in danger if people tolerate private powers...
Corporations, Adelson/Maher, AIPAC
...to an extent where these powers are
more powerful than the democratical state
itself.
That is the essence of fascism."
And it is hard to tell if the top dems are so out of touch but are actually repugs in dems clothing. Can anyone explain the difference between cheney and Obama, who seems to enjoy taking out civilians and supports big oil.
Adelson would prefer Romney because his authoritarian mindset is deeper than Obama's, but he can buy either one.
Notice how suddenly, after a few years, there are headlines about an investigation into "Fast and Furious?" And suddenly there are stories steering "The Conversation" into areas where things might have gone slightly better? I love Dennis Kucinich, who said that as much money as Solyndria lost, it lost much less than any nuclear power plant commonly loses, and is covered up. But does Dennis make headlines?
I NEVER click on any news story that is a (not so hidden) smear tactic. Sure there were some mistakes in Obama's Presidency, but in my entire lifetime (late 50s) there has NEVER been a President who has tried to achieve ANY healthcare package that would help young adults and middle class; and rarely a President who tried to help common people at all (let's see, the ones who did were all Democrats). Clean energy is still being talked about, and it wouldn't even be in "The Conversation" with Repugs running the country.
As far as being bought, Pres. Obama has tried to steer the ship; he has reduced and brought home forces from overseas. If it were Romney, these tired forces would be simply gearing up for Iran. You can talk to Pres. Obama; enough people telling him that Democrats need to be Democrats and he listens, but would you ever in your life get a Republican to listen to the needs of anybody who earns less than $250,000 a year?
Let's see - whose interests do you think a Pres. Romney would support? Sheldon "Mr. Greed" Adelson or the other 299 million Americans in the middle and "working" class? Hmmmm
If you care about the future of our country and our children, I'd suggest you don't vote for Sheldon Adelson (sorry - I mean, Mitt Romney).
...and so it goes, the Republicans are pitted against the Democrats and their supporters against each other and above the fray are the fat cats, Democrat and Republican alike, stuffing their pockets and grabbing power while we fight little battles amongst ourselves, trying to extinguish the little fires they set to divert us while the wholes system burns. Good night and good luck.
All I can toss into pot concerns the auctioning of our democracy.
It is a "silent" auction and we aren't invited.
The folks who own the construction companies contribute to Republicans, the road construction worker unions contribute to Democrats. They both lobby for crappy roads we have to replace every ten years. Good for their companies and jobs, bad for those of us who hate orange barrels.
Both sides buy influence.
Live with it, use it or figure out a way to fix it.
They're all traitors, Art947. These guys claim to be so "religious" and so "patriotic", but they're just the opposite. The Southern Christians and disparate hate groups despise Jews, Catholics, and Mormons, but they REALLY despise Blacks, Hispanics and any other people of color. So they're in. The other groups - regular conservatives, neo-conservativ es, the super-rich, libertarians, bankers, and corporations ("are people too") - who, incidentally, consider the Southern Christians and hate groups to be useful tools, manage to hold this unholy cabal together. So they're in.
Adelson and the others are awash with money. Shame of it is, the lemmings will follow them right into the sea. That's what we're up against.