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135839620
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JGR/Travel (5 of 6)
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135839620
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JGR/Travel (5 of 6)
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Records of the Office of Counsel to the President (Reagan Administration)
John Roberts' Subject Files
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1986-12-31
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Ronald Reagan Presidential Library Digital Library Collections This is a PDF of a folder from our textual collections. Collection: Roberts, John G.: Files Folder Title: JGR/Travel (5 of 6) Box: 55 To see more digitized collections visit: https://reaganlibrary.gov/archives/digital-library To see all Ronald Reagan Presidential Library inventories visit: https://reaganlibrary.gov/document-collection Contact a reference archivist at: [email protected] Citation Guidelines: https://reaganlibrary.gov/citing National Archives Catalogue: https://catalog.archives.gov/ THE WHITE HOUSE 2-27 WASHINGTON TO: LINAS. KOJELIS FROM: John G. Roberts, Jr. Associate Counsel Dre to the President FYI COMMENT ACTION THANKS FOR THE COPY OF YOUR LETTER TO DR K70 R. JHIN- LOOKS FINE. THE PARAGRAPH ON RECEIPTS PROMITS ME TO REMIND you, JUST TO BE ON THE SAFE SIDE, THAT THE FEDERATION MUST BE A 501(c)(3) ORGANIZATION IF IT IS To PICK UP AM OF YOUR EXPENSES. THE WHITE HOUSE WASHINGTON February 27, 1985 Dear Kyo: I would like to thank you and the executive committee of the Federation of Korean Associations for inviting me to be a part of your important program in New York last weekend. I am, of course, also very grateful for the handsome plaque and was very moved by this very generous gesture by your organization, as well as by your very kind introduction. I would also like to thank you for the very generous hono- rarium of $500.00. Unfortunately, White House staff policy does not allow me to accept honorariams for speaking engage- ments. Thus, I am returning the gift in the enclosed envelope. I am also enclosing two small travel receipts: $11.00 for cab fare and $6.00 for airport parking. It was good to see you in New York and I look forward to having lunch with you on the 11th. Sincerely, Liver Kojelis Associate Director Office of Public Liaison Dr. Kyo R. Jhin Senior Advisor The Federation of Korean Associations 7 Foxhall Ct. Silver Spring, MD 20906 bcc: John Roberts STATES MERICS THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE D. D73143108A 4 D WASHINGTON,D.C. 4 D207 E D73143108A 4 Katherine Devalor Outaga SERIES 1981 Danned Regan 4 the Septement the Innewal TOTAL TWENTYDOLLARS F1 UNITED STATES WAHE OF AMERICA THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE 2 D. 089402821 A FOR ALL DEBTS, PUBLIC AND PRIVATE 4 B TENDER LEGAL IS ROTE THIS SANANKS CANADA WASHINGTON,D.C. 4 E D Do D89402821A 4 SERIES 1981 the United States Danied Regan 4 P. ACKSON Secretary - the Treasury TWENTYDOLLARS UNITED STATES THE OF AMERICA THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE B55603903D G, 2 WASHINGTON,D.C. B00550880B B 3 2 WASHINGTON,D.C. 2 AMERICA G350 B55603903 D 2 SERIES 1981 David T. Regan David 2 Insurer the - Made JACKSON Security - an Treasury 20 TWENTY DOLLARS 20 UNITED STATES OF AMERICA THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE I 08245709 B C, 9 WASHINGTON,D.C. 9 I I08245709B Case 9 SERIES 1981 Danned Regan 9 Males Treasury THE UNITED STATES ORAMIERICA F2 THIS NOTE IS LEGAL TENDER FOR ALL DEBTS, PUBLIC AND PRIVATE A 01303697B 1 WASHINGTON.D.C. A 1 A01303697B 1 SERIES Danned Regan I 1981 - a Ended Makes & the 100 Transary Fee 100 PHONE AMAIL 100 THE UNITED STATES OFAMERICA 100 F2 THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE A 01303696B 1 THE WASHINGTON,D.C. A 1 A01303696B 1 SERIES 1981 Dansed Regan 1 Immoura the United ) Submary the Transury 100 Fa7 Z MART ONEHUNDREDDOLEARS 100 THINK UNITED STATES ORAMERICA 100 H₂ THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE B 20704982 B 2 WASHINGTON.D.C. 2 B YORK B 20704982 B SERIES 1961 Danned Regan 2 Insurers the Marks Sevedary of the Teasury Hios) 100 ONEHUNDREDDOLLARS 100 THE UNITED STATES OFAMERICA F2 THIS NOTE IS LEGAL TENDER FOR ALL DEBTS. PUBLIC AND PRIVATE A 01303698B 1 STATE WASHINGTON.D.C. 1 A A01303698B 1 SERIES 1981 Danied Regan 1 Security & the Transury Fice 100 100 file THE WHITE HOUSE WASHINGTON Travel expenses May 13, 1985 John: I called you on the matter of travel and accomodations reimbursement regarding the invitation the U. of Texas at Houston. Anne Higgins told me to check this out with you folk. Here's a copy of the invitation and material on U.T's tax status. Please advise. Thanks m.Batton Mike Batten 7486 UNIVERSITY OF TEXAS MEDICAL STATES POSTA PO BOX 20708 HOUSTON TX 77225 09PM Western Union Mailgram ® UNITED SERVICE U.S.MAIL 1-0357208129 05/09/85 ICS IPMBNGZ CSP WHSB 7137924711 MGMB TDBN HOUSTON TX 89 05-09 0402P EST MR MICHAEL D BATTEN, MuAs AGENCY LIAISON THE WHITE HOUSE WASHINGTON DC 20500 WE WOULD LIKE TO INVITE YOU TO THE UNIVERSITY OF TEXAS MEDICAL SCHOOL AT HOUSTON TO MEET WITH ADMINISTRATION AND FACILITY AND PROVIDE INFORMATION ON ORGAN TRANSPLANT PROGRAMS. YOUR TRANSPORTATION AND ACCOMMODATIONS WILL BE PAID FOR BY THE UNIVERSITY OF TEXAS, WE PLAN ON YOUR BEING PRESENT ON MAY 17 AND 18 AND LOOK FORWARD TO RECEIVING YOUR VALUED COUNSEL. ALBERT E GUNN MD, ASSOC, DEAN FOR ADMISSIONS UNIVERSITY OF TEXAS MEDICAL SCHOOL AT HOUSTON ON 19811 EST MGMCOMP TO REPLY BY MAILGRAM MESSAGE, SEE REVERSE SIDE FOR WESTERN UNION'S TOLL FREE PHONE NUMBERS Internal Revenue Service Department of the Treasury Index Nos.: 0115.00-00 0170.00-00 Washington, DC 20224 2522.00-00 0509.00-00 4041.00-00 Person to Contact: University of Texas System Robert D. Patchell 201 W. 7th Street Telephone Number: Austin, TX 78701 (202) 566-3626 Refer Reply to: CC:IND:I:3:2 - 3F2436 Date: 20 MAR 1984 University System = University of Texas System EIN: 74-6000203 DO 74 TY 84 B = University of Texas at Arlington C = University of Texas at Austin D = University of Texas at Dallas E = University of Texas at E1 Paso F = University of Texas of the Permian Basin G = University of Texas at San Antonio H = University of Texas at Tyler I = University of Texas Institute of Texan Cultures at San Antonio J = University of Texas Health Science Center at Dallas K = University of Texas Medical Branch at Galveston L = University of Texas Health Science Center at Houston M = University of Texas Health Science Center at San Antonio N = University of Texas System Cancer Center 0 = University of Texas Health Center at Tyler State = State of Texas Board = Board of Regents of the University of Texas System University = University of Texas Dear Sir or Madam: This is in response to a letter submitted on behalf of the University System and its component institutions request- ing rulings concerning the tax status of these organizations. According to the information submitted, the establish- ment of the University was mandated by section 10, article 7 of the constitution of State. Subsequently, the legislature -2- University of Texas System established the University System under section 65.02 of Title 3, Tex. Education Code Ann. (Vernon) and organized thereunder the University and its component educational institutions listed as following: B, C, D, E, F, G, H, I, J, K, L, M, N, and 0 (collectively referred to as the "University System"). Statutory provisions vest the management, operation and control of the University System in the Board. Nine individuals, appointed by the governor of State with the advice and consent of the senate, serve on the Board and are included within the statutory definition of state employees. Additionally, the treasurer of the State has been designated as the treasurer of the University System. The Board is authorized to prescribe the courses and programs of study that are required to obtain a degree from any of the component institutions in the University System. However, the Board may not establish a four-year undergraduate degree program at a component institution that has not been authorized to do so by specific legisla- tion without obtaining prior approval by a two-thirds vote of the coordinating board of the University System and a specific act of the legislature. The Board is empowered to make appointments in the component institutions under its control. In its dis- cretion, the Board may also remove any officer, member of the faculty, or employee connected with the University System. The Board is authorized to accept gifts and donations for the benefit of the University System and any of its component institutions. Additionally, the Board has the power of eminent domain to acquire any land that may be necessary for the use of the University System and the taking of such property has been declared to be for the use of the State. Section 115(1) of the Internal Revenue Code provides that gross income does not include income derived from any public utility or the exercise of any essential governmental function and accruing to a state or any political subdivision thereof. -3- University of Texas System Section 115 of the Code does not apply to the states or their political subdivisions, such as counties or towns (or integral parts thereof). Generally, the activities of states and their political subdivisions are exempt from federal income taxation in accordance with the constitutional law doctrine of intergovernmental tax immunity. Also, see Rev. Rul. 71-131, 1971-1 C.B. 28 and Rev. Rul. 71-132, 1971-1 C.B. 29, which hold that income derived from the operation of liquor stores by a state is not subject to federal income tax. Thus, section 115 only applies to organizations that are separate and apart from the state and its political subdivisions. Based on the information submitted, we conclude that section 115 of the Code does not apply to the income of the University System and its component institutions because they are not organizations established separately from the State. The activities and organizational structure of the University System and its component institutions are established as an integral part of the State's public education program. Therefore, we conclude that the University System and its component institutions are not subject to federal income taxation because they are agencies within State's government. Section 170( (a) of the Code provides, subject to certain limitations, a deduction for contributions and gifts to or for the use of organizations described in section 170(c), payment of which is made within the taxable year. Section 170(c)(1) of the Code provides, in part, that the term "charitable contribution" means a contribution or gift to or for the use of a state or any political subdivision thereof, but only if the contribution or gift is made exclusively for public purposes. Section 170(b) of the Code provides, in part, that in the case of an individual, the deduction provided in section 170(a) shall be allowed for any charitable con- tribution to a governmental unit referred to in section 170 (c) (1) to the extent that the aggregate of such con- tributions does not exceed 50 percent of the taxpayer's contribution base for the taxable year. -4- University of Texas System Because we have determined that the University System and its component institutions are agencies within State's government, these organizations are described in sections 170(b) (v) and 170 (c) (1). Therefore, we conclude that con- tributions to the University System and its component insti- tutions are deductible by donors under section 170 of the Code provided such contributions are made for exlusively public purposes. Section 2522 (a) (1) of the Code provides that in deter- mining the amount of taxable gifts for the calendar year there may be deducted in the case of a donor who was a citizen or resident of the United States at the time the gifts were made, all gifts included in the "total amount of gifts" made by the donor during the calendar year which were made to or for the use of the United States, any state or political subdivision thereof or the District of Columbia for exclusively public purposes. Section 4.04 of Rev. Proc. 84-1, 1984-1 I.R.B. 10 provides that no gift tax ruling may be issued except to an actual taxpayer upon a specific set of facts. For purposes of the gift tax, the taxpayer is the donor. However, to the extent that the University System is a charity described in section 2522 (a) (1) of the Code and all other requirements of section 2522 are met at the time of the gift, transfers to the University System and its component institutions will meet the requirements of that section of the Code. We regret that we are unable to issue rulings with respect to sections 2055 and 2106 of the Code. Section 5.02 of Rev. Proc. 84-1 provides that the National Office will not rule on matters relating to the application of the estate tax to the property or estate of a living person. We also are unable to issue a ruling as to the appli- cation of section 2602 of the Code. Section 5.02(1) of the foregoing Rev. Proc. provides that rulings are not issued until after the generation skipping trust, or trust equivalent, has been established. Rulings are not issued on a generation skipping transfer tax matter before distri- bution or termination takes place. -5- University of Texas System Section 4041 (g) (2) of the Code exempts from the taxes on diesel and special motor fuels imposed by section 4041 sales for the exclusive use of any state, political subdivision thereof, or the District of Columbia. Comparable exemptions from the tax on fuel used in commercial transportation on inland waterways, the tax on heavy trucks and trailers, the manufacturers excise taxes, the tax on communications and the highway use tax are provided by sections 4042(e) (3), 4053(b), 4221 (a) (4), 4253(i), and 4483(a), respectively. Also, section 4991 (b) (1) of the Code exempts oil from the windfall profit tax imposed by section 4986 where the oil is from an economic interest held by a state or political subdivision thereof and all the net income therefrom is dedicated to a public purpose. Because the University System and its component insti- tutions are a part of the State, they qualify for the state exemptions from federal excise taxes cited above. Section 2 of Rev. Proc. 84-1 provides that procedures for obtaining rulings that apply specifically to federal firearms taxes under subtitle E of the Code are under the jurisdiction of the Bureau of Alcohol, Tobacco and Fire- arms. Therefore, we are unable to issue rulings with respect to sections 5123, 5214, 5362, and 5853 of the Code. Section 509 (a) of the Code provides that the term private foundation means a domestic or foreign organization described in section 501 (c) (3) other than an organization described in section 170 (b) (1) (A). Section 501 (c) (1) provides for the exemption of cor- porations organized under Act of Congress, if such corpora- tions are instrumentalities of the United States and if, under such Act, as amended and supplemented, such corpora- tions are exempt from federal income taxes. Section 501 (c) (3) of the Code provides for the exemption from federal income tax of organizations organized and operated exclusively for charitable, educational, religious, or scientific purposes, no part of the net earnings of which inures to the benefit of any private shareholder or individual. -6- University of Texas System Section 6033 (a) (1) of the Code provides that, except as provided in paragraph (2), every organization exempt from taxation under section 501 (a) shall file an annual return, stating specifically the items of gross income, receipts and disbursements and such other information for the purpose of carrying out the internal revenue laws as the Secretary may by forms or regulations prescribe. Section 1.6033-2(g (1) provides that a state institu- tion, the income of which is excluded from gross income under section 115(a), and which is otherwise exempt under section 501 (a) is not required to file an annual information return on Form 990. Rev. Rul. 60-384, 1960-2 C.B. 172 provides that a wholly- owned state or municipal instrumentality which is a separate entity (emphasis added) and which is organized and operated exclusively for purposes described in section 501 (c) (3) of the Code may qualify for exemption. A state or municipality itself, however, would not qualify as an organization described in section 501 (c) (3). Chapter 13 of the Exempt Organizations Business/Master File Handbook provides guidelines and procedures for listing organizations in the Cumulative List of Organizations in Publication 78 (Pub. 78). Generally, the organizations listed in Pub. 78 are those that have applied for, and received a determination or ruling letter recognizing them to be exempt under section 501 (c) (3). Since the University System and its component institutions have not applied for recognition of exemption under section 501 (c) (3) and received a ruling or determination letter favorably recognizing such status and are not organizations exempt under section 501 (c) (1), they do not meet the criteria for listing in Pub. 78. The University System and its component institutions were removed from the Exempt Organizations Master File because they had been erroneously listed as organizations recognized to be exempt under section 501 (c) (1). No opinion is expressed as to the federal income tax consequences of the transaction described above under any -7- University of Texas System other provision of the Code. This ruling is directed only to the organizations that requested it. Section 6110(j) (3) of the Code provides that it may not be used or cited as precedent. In accordance with the power of attorney on file with this office, a copy of this letter is being sent to your authorized representative. Sincerely yours, Richard # manfreda Chief, Individual Income Tax Branch Enclosures 2 Copy of this letter Copy for section 6110 purposes THE WHITE HOUSE WASHINGTON June 13, 1985 MEMORANDUM FOR FRED F. FIELDING FROM: JOHN G. ROBERTS SUBJECT: Travel Inquiry B. Oglesby has been invited to speak at the annual dinner of the Brunswick-Golden Isles Chamber of Commerce at the Cloister Hotel on Sea Island, Georgia. His wife has been invited as well. B. has asked whether he may accept trans- portation (private aircraft) and travel expenses from the Chamber. The Chamber is not a 501 (c) (3) organization, and accordingly B. may not accept transportation or travel expenses for himself. In particular, he should not travel on the Chamber aircraft. As we discussed this morning, since the Chamber may not pay for B.'s travel it may not pay for his wife's. The foregoing assumes that the travel is official, which I think is the correct assumption. Attachment THE WHITE HOUSE WASHINGTON June 13, 1985 MEMORANDUM FOR M. B. OGLESBY, JR. ASSISTANT TO THE PRESIDENT FOR LEGISLATIVE AFFAIRS FROM: FRED F. FIELDING Orig, signed by TIP COUNSEL TO THE PRESIDENT SUBJECT: Travel Inquiry You have asked if the Brunswick-Golden Isles Chamber of Commerce may pay your travel expenses, and those of your wife, in connection with an invitation for you to address their annual convention. The invitation would have to be considered to have been extended to you in your official capacity, and accordingly you may accept reimbursement of travel expenses only from a 501 (c) (3) organization. The Chamber is not such an organization. Since the Chamber may not pay for your travel, it may not pay for that of your spouse. In particular, you should not travel on the Chamber's private aircraft. FFF: JGR:aea 6/13/85 CC: FFFielding JGRoberts Subj Chron 323179 ID # CU Dg WHITE HOUSE FG006-01 CORRESPONDENCE TRACKING WORKSHEET o . OUTGOING H . INTERNAL JR. I - INCOMING Date Correspondence Received (YY/MM/DD) / Name of Correspondent: M.B.Oglesky MI Mail Report User Codes: (A) (B) (C) Subject: acceptance of travel expenses for speaking engagement to the Brunnwich - Golden Jales Chamber of Commerce ROUTE TO: ACTION DISPOSITION Tracking Type Completion Action Date of Date Office/Agency (Staff Name) Code YY/MM/DD Response Code YY/MM/DD OUHOLL 85,06,11 PY ORIGINATOR / / Referral Note: CUAT 18 1) 85,06,12 PY 5.85106,22 Referral Note: / / / / Referral Note: / / I / Referral Note: / / / / - Referral Note: ACTION CODES: DISPOSITION CODES: A Appropriate Action I - Info Copy Only/No Action Necessary A Answered C Completed C Comment/Recommendation R. Direct Reply w/Copy B - Non-Special Referral S Suspended D Draft Response S For Signature F Furnish Fact Sheet X Interim Reply to be used as Enclosure FOR OUTGOING CORRESPONDENCE: Type of Response = Initials of Signer Code = "A" Completion Date = Date of Outgoing Comments: Keep this worksheet attached to the original incoming letter. Send all routing updates to Central Reference (Room 75, OEOB). Always return completed correspondence record to Central Files. Refer questions about the correspondence tracking system to Central Reference, ext. 2590. 5/81 323179 THE WHITE HOUSE WASHINGTON June 11, 1985 MEMORANDUM FOR FRED FIELDING FROM: M. B. OGLESBY, JR I have been invited to speak to the Brunswick-Golden Isles Chamber of Commerce's annual dinner on Friday, June 21, in Sea Island, Georgia (letter of invitation attached). The Chamber has invited my wife as well. This memo is to seek specific guidance from your office with regard to acceptance of travel expenses that will be incurred during this trip. For your information, the Chamber has offered transportation (private aircraft) to facilitate my work schedule. Thank you for your assistance. B YES FYI t BRUNSWICK GOLDEN ISLES CHAMBER OF COMMERCE Box 250, Brunswick, Georgia 31521 Telephone 912-265-0620 May 24, 1985 Office of the President Mr. M. B. Oglesby Assistant to the President for Legislative Affairs The White House Washington, D. C. 20005 Dear Mr. Oglesby: This letter is to confirm your acceptance to speak at our annual dinner on Friday, June 21st at the Cloister Hotel, Sea Island, Georgia. We have made arrangements for you to be our guest at the Cloister on Friday, June 21st and Saturday, June 22nd. We will be back in touch with you to arrange for your transportation. We would appreciate it if prior to the 21st you would send us a biographical sketch from which we might write a proper introduction. We look forward to having you visit the Golden Isles and speak to our Chamber of Commerce. IV Yours @Wildow truly, H. P. Weldon (va Sanders) HPW: vns his it > Xt is las 55 For &SAT Nine LEAVE Sun. BRUNSWICK ENVLL D GEORGIA THE WHITE HOUSE WASHINGTON August 23, 1985 MEMORANDUM FOR FRED MCCLURE SPECIAL ASSISTANT TO THE PRESIDENT FOR LEGISLATIVE AFFAIRS FROM: ASSOCIATE COUNSEL TO THE PRESIDENT JOHN G. ROBERTS OZR SUBJECT: Approval of Speaking Invitation from Breckenridge (Texas) Chamber of Commerce You have asked this office to approve your acceptance of travel expenses from the Breckenridge Chamber of Commerce, in connection with an invitation extended to you to partici- pate as guest speaker at the Chamber's annual banquet. You have indicated that you would speak on the Administration's programs and policies at the banquet. The Chamber is a 501 (c) (6) organization. Federal law permits acceptance of travel expenses incurred in official travel only from 501 (c) (3) organizations. 5 U.S.C. § 4111. Accordingly, if your travel is determined to be official travel, you may not accept reimbursement of expenses from the Chamber, or arrange to have the Chamber pay your travel expenses. In our view, travel in connection with an address to an organization such as the Chamber on Administration programs and policies must be considered official travel. As noted in the White House Travel Handbook, "as a rule of thumb, if your travel is in furtherance of your official duties or the Administration's policies, it should be considered as "official" travel for purposes of determining whether you may accept expenses." Accordingly, your travel expenses must be paid for from appropriated funds. #). 334614 ID # CU FGOOG OI WHITE HOUSE CORRESPONDENCE TRACKING WORKSHEET o - OUTGOING JR-dering H . INTERNAL 1 . INCOMING Date Correspondence Received (YY/MM/DD) Name of Correspondent: Fred mecluse MI Mail Report User Codes: (A) (B) (C) Subject: approval of speahing Invitation from commerce Brechensidge t Texas) chamber as ROUTE TO: ACTION DISPOSITION Tracking Type Completion Action Date of Date Office/Agency (Staff Name) Code YY/MM/DD Response Code YY/MM/DD cultau ORIGINATOR 85,07,30 1 1 Referral Note: cuat 18 R 851073172 $ 85,08,11 Referral Note: / 1 1 1 Referral Note: / 1 1 1 Referral Note: 1 1 1 1 Referral Note: ACTION CODES: DISPOSITION CODES: A - Appropriate Action Copy Dniy/No Action Necessary A Answered c Completed c - Comment/Recommendation R . Direct Reply w/Copy B - Non-Special Referral S Suspended D Draft Response $ For Signature F - Furnish Fact Sheet Interim Reply to be used as Enclosure FOR OUTGOING CORRESPONDENCE: Type of Response = Initials of Signer Code = "A" Completion Date = Date of Outgoing Comments: Keep this worksheet attached to the original incoming letter. Send all routing updates to Central Reference (Room 75, OEOB). Always return completed correspondence record to Central Files. Refer questions about the correspondence tracking system to Central Reference, ext. 2590. 5/81 MEMORANDUM THE WHITE HOUSE WASHINGTON July 26, 1985 4 cu TO: FRED FIELDING Counsel to the President THROUGH: MAX L. FRIEDERSDORE M.B. OGLESBY, JR. mef PAMELA J. TURNER 7ml FROM: FRED McCLURE Special Assistant to the President for Legislative Affairs SUBJECT: Approval of Speaking Invitation from Non-Profit Organization Pursuant to section 5 (A) of the White House Standards of Conduct relating to "Travel Related Expenses," approval is hearby sought for authority to accept an invitation from the Breckenridge (Texas) Chamber of Commerce. The invitation was not extended to me in my official capacity as a member of the White House staff. The Chamber is exempt from taxation under the Internal Revenue Code, 26 U.S.C. § 501 (c) (6). It is a " chamber (s) of commerce not organized for profit and no part of the net earnings of which inures to the benefit of any private shareholder or individual." The invitation extended is for me to participate as the guest speaker at the Annual Banquet of the Chamber during the week of February 16, 1986 (a final date has not been selected), in Breckenridge, Texas. The organization proposes to pay for my normal, reasonable travel expenses. In my view, should I accept this invitation, it will not create an actual or apparent conflict of interest with my official duties if the Chamber reimburses me in the manner described, supra. Further, I understand that the reimbursement must be disclosed on my annual Executive Personnel Financial Disclosure Report (SF-278), pursuant to 5 U.S.C. app. 4 § 201 (a), 5 C.F.R. § 734.604. MEMORANDUM TO FRED FIELDING June 5, 1985 Page Two Should you need additional information concerning this request, please contact me at extension 6782. Approve Date Signature Disapprove Date Signature