# Political Payola (`politicalpayola.com`) — IRS Section 501(c)(3) Nonpartisanship & Private Foundation Grant Compliance Statement

**Document Purpose:** Official legal and programmatic compliance attestation for **501(c)(3) Fiscal Sponsors** (Open Source Collective, Hack Club HCB, Tiny News Collective, Hacks/Hackers) and **Institutional Grantmakers** (Knight Foundation, Democracy Fund, Colorado Media Project, El Pomar Foundation, Gates Family Foundation, Mozilla Foundation, MacArthur Foundation).

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## 1. Compliance with IRS Revenue Ruling 2007-41 & Revenue Ruling 78-248 (Nonpartisan Voter Education)
Under **Internal Revenue Code § 501(c)(3)** and **IRS Revenue Rulings 78-248 and 2007-41**, compiling and publishing voting records, campaign finance disclosures, and public policy outcomes is a valid tax-exempt **charitable and educational activity** when conducted according to four strict criteria. Political Payola satisfies all four:

1. **No Express or Implied Endorsements:** Political Payola never endorses or opposes any candidate for public office, never labels lawmakers as "pro-family" or "anti-family" with partisan grades, and never instructs citizens on how to vote.
2. **Broad Range of Issues:** The platform covers **26 distinct civic, economic, public-health, environmental, judicial, and legislative modules** (5,309 total records spanning 1981–2026), rather than a narrow single-issue litmus test.
3. **Complete & Unbiased Coverage of All Legislators:** All **539 members of the 119th U.S. Congress** (100 Senators, 435 Representatives, and non-voting delegates) and all **50 U.S. states + D.C.** are indexed using identical quantitative metrics (`FEC.gov` receipts, `Congress.gov` roll-call votes, `CBO` deficit scores, and DOJ/Ethics dockets). In our 177-case corruption archive, both parties are documented strictly by court/ethics docket (**93 Democrats · 84 Republicans**).
4. **No Election-Timing Manipulation:** Dataset updates follow official federal release schedules (`FEC` quarterly filings, `Congress.gov` roll-call tallies, `CDC`/`Census` annual releases) year-round and are published as permanent open-access educational datasets (`CC-BY-4.0`).

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## 2. Compliance with IRC § 4945(d)(1) (Zero Lobbying With Foundation Grant Funds)
Private foundations (such as the Knight Foundation, Gates Family Foundation, El Pomar Foundation, and Mozilla Foundation) are prohibited under **IRC § 4945(d)(1)** and **Treas. Reg. § 53.4945-2** from funding "attempts to influence legislation" (direct or grassroots lobbying).

Political Payola enforces a strict mechanical compliance boundary on the live web application:
- **Nonpartisan Educational Analysis & Research Exception (`Treas. Reg. § 53.4945-2(d)(1)`):** All legislative summaries on `politicalpayola.com` present both major parties' roll-call votes (`Yea` vs. `Nay` by caucus), official Congressional Budget Office (`CBO`) cost estimates, and links to full statutory text on `Congress.gov` so citizens can reach their own independent conclusions.
- **No "Call to Action" Lobbying Petitions:** The platform's **Nonpartisan Civic Literacy & Representative Lookup Center** provides neutral directory lookup of a citizen's U.S. Senators and House Representative, official `Congress.gov` bill texts, and printable classroom comparison worksheets — without partisan petitions urging Congress to vote for or against pending legislation.
- **100% Charitable & Educational Grant Budget Allocation:** Every dollar of philanthropic grant funding is restricted to:
  1. **Primary-Source Data Engineering & Verification ($35,000):** Automated `validate_data.py` link checking, FEC/Congress/CBO ingestion, and `.well-known/mcp.json` / `/api/tools.json` schema maintenance.
  2. **Bilingual (`EN/ES`) Grade-10 Literacy & Title I Classroom Outreach ($25,000):** Spanish-language parity auditing and free curriculum distribution across Pueblo (`D60`/`D70`), Southern Colorado, and rural school districts.
  3. **Open-Access Hosting, Rural 3G Optimization & Fiscal Sponsor Administration ($15,000):** Zero-paywall CDN delivery, WCAG 2.1 AA accessibility compliance, and 501(c)(3) fiscal sponsor oversight.