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President - Swimming Pool (3)
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President - Swimming Pool (3)
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Philip W. Buchen Files
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The original documents are located in Box 55, folder "President - Swimming Pool (3)" of the Philip Buchen Files at the Gerald R. Ford Presidential Library. Copyright Notice The copyright law of the United States (Title 17, United States Code) governs the making of photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United States of America his copyrights in all of his unpublished writings in National Archives collections. Works prepared by U.S. Government employees as part of their official duties are in the public domain. The copyrights to materials written by other individuals or organizations are presumed to remain with them. If you think any of the information displayed in the PDF is subject to a valid copyright claim, please contact the Gerald R. Ford Presidential Library. Digitized from Box 55 of the Philip Buchen Files at the Gerald R. Ford Presidential Library Swimming THE WHITE HOUSE WASHINGTON pool May 2, 1975 MEMORANDUM TO: WARREN RUSTAND FROM: JACK MARSH In the preparation of the background paper for the Marriott visit to the President on Monday, May 5, I am supplying some information you may already have. Mr. Marriott met with me this week on another matter, which I expect will come up in his discussion on Monday, although it is not the principal purpose of his visit. This new subject relates to a gift of funds by the Inaugural Committee to the National Parks Foundation for the purpose of constructing the swimming pool at the White House. The principal reason Mr. Marriott is seeing the President, I understand relates to the Bicentennial. On that subject, he indicated he would like to discuss the following: 1) The President's schedule for Saturday evening, July 3, 1976 to observe the Bicentennial. He suggests a program at the Kennedy Center, featuring prominent American leaders and entertainers, i.e., Billy Graham, Bob Hope, etc., at which time the President would extend a Bicentennial message to the world carried by satelite. 2) He wishes to ascertain the views of the President on the Honor America Day Committee, of which Mr. Marriott is Chairman. (You should note that the President is already carried on the letterhead as a Congressional sponsor of the Committee, relating back to his Congressional service.) 3) He would like to have the President serve as Honorary Chairman of Honor America Day. 4) He'd like to have Mrs. Ford named to an Honorary post of FORD national significance, perhaps Chairlady of the 3 July, 1976 event. LIBRARY -2- 5) He'd like to have the Honor America Day Committee meet for a regular meeting at the White House, followed by a reception. Finally, and unrelated to subjects just mentioned, he may wish to seek the President's view as to Inaugural Committee Director for 1976 - 1977. CC: PBuchen DRumsfeld LISA GERALD = FORD THE WHITE HOUSE WASHINGTON May 2, 1975 no: ROD HILLS FROM: RUSSELL A. ROURKE For Direct Reply For Draft Response X For Your Information Please advise See Page 2. GERALD FORD LIBRA, MAY 2 19/5 THE WHITE HOUSE WASHINGTON Date: 5/2 TO: RUSSELL ROURKE FROM: DAVID C. HOOPES FYI: [ ] Comment: Russ -- Could you please give this a quick look-over to see if you have any problems? Thank you. THE WHITE HOUSE WASHINGTON May 2, 1975 MEETING WITH J. WILLARD MARRIOTT Monday, May 5, 1975 12:30 p.m. (10 minutes) The Oval Office From: David C. Hoopes A I. PURPOSE To meet with Bill Marriott and discuss several items needing your attention. II. BACKGROUND, PARTICIPANTS & PRESS PLAN A. Background: You last saw him in Scottsdale, Arizona, on November 14, 1974, when he accompanied you back to Washington on Air Force One. He was the Chairman of the 1973 Inaugural Committee. The Committee budget is approximately $300, 000, which IS protit from the 1973 Inaugural. B. Participants: J. Willard Marriott C. Press Plan: David Hume Kennerly photo only III. TALKING POINTS 1. July 3-5, 1976, Bicentennial Celebration As Chairman of Honor America Day, he plans a patriotic entertainment event at the John F. Kennedy Center for the Performing Arts on the evening of Saturday, July 3, 1976, to permit prime-time national and world-wide TV coverage. Top entertainers together with the Salt Lake Mormon Tabernacle Choir would join with you in a patriotic message to the Nation. Billy Graham is now giving some thought to ways to stress the religious aspect of the Bicentennial on Sunday, July 4, and Bob Jani of Disney Productions, Inc., has also discussed with SEAL FORD Marriott and others ideas for Monday, July 5 celebration. LIBRARY 1. -2- He feels strongly that the entertainment-patriotic aspects of the Bicentennial celebration should be limited to Saturday and Monday, and that July 4 itself should be reserved for religious events throughout the Nation in local churches. Recommended Response I appreciate all the work you are doing to plan the July 3, 1976, event and I hope you will continue to work with Warren Rustand, who will make preparations for my participation. x 2. White House Swimming Pool He may bring up the proposed swimming pool plan. He is anxious to be of assistance by providing either a loan or an outright grant from the Inaugural Committee funds. Marriott has twice in the past used funds from the 1969 Inaugural Committee to assist the National Park Service Foundation. In April 1970, the Inaugural Committee gave $100, 000 to assist in the lighting of the White House and in November 1972, it gave $75,000 for redecorating and refurbishing public rooms in the White House, both gifts having been accepted by the National Park Service under the Act of July 10, 1935; 49 Stat. 478, 16 USC. (6)a. For that reason, he feels it is appropriate to donate funds from the 1973 Inaugural Committee to assist with the construction of the $200, 000 swimming pool at the White House. Recommended Response When I make a final decision on the matter of the pool, I'll have Jack Marsh let you know. He will be in touch with you concerning the pool, if that seems the most appropriate way to proceed. I know you have already discussed the subject with him (Marriott saw Marsh on Friday.) 3. Corporate Tax Credit to Solve Unemployment He feels strongly that a tax incentive should be given to corporations for hiring more people (i.e. 5%) then during a previous base period of time (i.e., 12-18 months) to solve the Nation's unemployment. He feels this would be more effective than the Government paying unemployment comepnsation because the economy would grow and the reduced corporate taxes would serve as a viable incentive to hiring the enemployed. - -3- Recommended Response This is a good idea and I will pass it on to Bill Seidman and see if he can include it in some of our future legislative plans. 4. 1977 Inaugural Executive Director He will recommend that you consider appointing an executive director for the 1977 Inaugural. Committee before March 1976, so that that person can begin making arrangements for office space and other housekeeping chores before the election. Traditionally, after the election the President-elect designates the Inaugural Chairman. Recommended Response I'll have Bill Walker start looking at candidates immediately to ensure we have him ready to begin work early next year as you recommend. FORD : 07/830 LIBRARY THE WHITE HOUSE WASHINGTON May 8, 1975 MEMORANDUM FOR: JACK MARSH FROM: RODERICK HILLS You asked that I articulate those reasons which make it undesirable to utilize funds of the Inaugural Committee for the proposed White House swimming pool. Simply stated, those reasons are: (i) There is an appearance of illegality in the granting of such funds by the Inaugural Committee for the proposed swimming pool and (ii) it is difficult to establish as a public relations matter that the Inaugural Committee funds are not funds collected for former President Nixon for his disposition (i. e., Nixon money). (i) The Appearance of Illegality. The applicable statutes provide for the appointment of an Inaugural Chairman by the President-Elect. Once appointed, that Chairman appears to have full authority to appoint all other members of the Inaugural Committee and to unilaterally provide for the collection of funds and the disbursement of funds in connec- tion with the Inaugural activities. Mr. Marriott was appointed by former President Nixon. In an efficient and businesslike fashion, he arranged contracts with the Franklin Mint and others to sell certain souvenirs, primarily medals, and set ticket prices in order to fund the Inaugural activities. His efforts caused far more funds to be collected than were in fact needed for the Inaugural activities. At the request of the White House, he hired a number of White House personnel and a number of campaign workers to run FORD GERALD LIBRARY -2- the Inaugural activities. In prior years, substantially all of the work was done by volunteers who were not paid. Following the completion of the Inaugural, certain employees (e. g., Messrs. Magruder and Porter) were continued on the Inaugural payroll until they found gainful employment elsewhere. Such payments were made to these employees at White House request. The appearance of illegality is based upon the extraordinary authority apparently given and exercised by the Chairman of the Inaugural Committee with no other limitations than the desires of the President and those of the Internal Revenue Service which have been interpreted as requiring the surplus funds to be used for charitable type activities to avoid losing the non-profit tax free status that the organization enjoys. It may be that the unilaterally controlled spending of monies in this fashion is perfectly legal so far as a court may be concerned. But it is an unusual procedure and one that could be subject to considerable abuse if the funds were not in the hands of a person of such high moral character as Mr. Marriott. Moreover, if the procedures were highlighted there could well be a demand for broad public scrutiny in a way that could be most disturbing both to the White House and Mr. Marriott. One could argue, for example, that the supporting of Messrs. Magruder and Porter after the Inaugural was completed was in fact not a proper use of funds and should be investigated by the Internal Revenue Service to put the tax status of the organization in jeopardy. More important, since there have been considerable public complaints that the Nixon campaign funds were illegally collected and illegally spent, one can anticipate the possibility of a public demand for a close investigation of the source and use of Inaugural funds. (ii) The Inaugural Funds as Funds of Former President Nixon. Historically, all Inaugural Chairmen, having been appointed by the President-Elect, are necessarily responsive to the President-Elect's desires as to how the funds should ReFORD expended. Since Chairman Marriott was appointed by former GERABO LIBRARY -3- President Nixon, he was appropriately responsive to Mr. Nixon's desires. The argument that all prior disbursals of Inaugural funds, as well as the disbursal of Inaugural funds for the White House swimming pool, are made with the consent of or at the request of former President Nixon would be hard to rebut conclusively. If called to public attention, it would be particularly hard to avoid the argument that surplus Inaugural Committee funds were spent to support Messrs. Magruder and Porter, et al., at the request of the former President, and any funds to be used for a White House swimming pool would similarly infer the assent if not the request of the former President. FORD is LIBRARY 07V839 THE WHITE HOUSE WASHINGTON May 12, 1975 MEMORANDUM TO: PHIL BUCHEN FROM: RUSS ROURKE R Phil, for your information, it has been suggested that the title of White House Swimming Pool Committee, adopted by the "Study Committee" last September be continued in use and that the attached Committee membership be retained, with A. J. Sehorn continuing as Chairman. As per my previous memo, Bill Schuiling will serve as Treasurer. (Bill Casselman is, I am sure, more familiar than I with the "White House Swimming Pool Committee" organization of last fall.) FORD is QERALO LIBRARY WHITE HOUSE SWIMMING POOL COMMITTEE A. J. Sehorn Vice CHAIRMAN Carboline Marine Corporation 24353 Clawiter Rd. Hayward, Ca. 94545 415-893-1062 415-968-1537 1976 U.S olympic Dr. James Counsilman John B. Kelly, Jr. chareman SWIMI A COAGH Indiana University 1720 Cherry St. Bloomington, Ind. 47401 812-337-6788 Philadelphia, Pa. 19103 215-561-6400 215-561-1373 Dr. John A. Bogert 4240 Blue Ridge Blvd. William P. Market r winstituteng Po Dir.of Public Mikansas City, Mo. 64133 816-229-3526 2000 K Street, N. Swim 816-353-7200 Washington, D.C. 20006 202-331-8844 301-229-7115 Peter Daland Formstmpic 1963 Elmsbury swim Westlake Village, Ca. 91361 Charles F. McCaffree, Jr. 435 Bailey Street Mich 213-889-2057 comeh East Lansing, Mich. 48823 517-332-2757 William F. Dawson #1 Hall of Fame Drive Jack W. Nelson fees: Swim HSSN Ft. Lauderdale, Fla. 305-524-6536 1501 N, E. 62nd Street Ft. Lauderdale, Fla. 33308 305-772-7859 305-772-1460 305-772-1001 George F. Haines, Athletic Dept. DISECTS USOLYMP.C University of California at LA Robert M. Ousley Los Angeles, Ca. 90024 Box 14 213-825-3236 Pompano Beach, Fla. 33061 305-524-6267 Phil Hansel 1976 305-946-3935 7711 Prestwood Drive Houston, Texas 77036 713-781-7822 Kenneth Treadway Phillips Petroleum Co. Swins Cam Richard E. Harkins 4 C 4 Phillips Bldg. of 201 East Armour Blvd. Bartlesville, Okla. 74003 winn 918-661-6210 Kansas City, Mo. 64111 816-931-6277 918-333-3595 816-761-9339 GERALD FORD EIBRAN THE WHITE HOUSE WASHINGTON May 12, 1975 MEMORANDUM TO: PHIL BUCHEN FROM: RUSS ROURKE R Phil, we now have our Treasurer, viz., Mr. William J. Schuiling, President and Chief Executive Officer, Finance General Bank Shares, Inc. Jack Stiles tells me that the aforementioned Corporation is the parent company of the First National Bank of Washington. Jack Stiles spoke with Schuiling personally last week and this morning. Last week, Schuiling agreed to make a $500 personal contribution and this morning he accepted the position I have men- tioned. FYI, Bill Schuiling was responsible for President Ford's only election defeat, viz., class President of South High School, Grand Rapids, Michigan. That was also the only election Schuiling ever won. The Committee does not as yet have a name that will be determined in the next day or two. FORD is 078830 LIBRARY THE WHITE HOUSE WASHINGTON May 12, 1975 MEMORANDUM FOR: JACK MARSH FROM: BILL CASSELMAN BR SUBJECT: Swimming Pool Per your request, attached at Tab A is a checklist of legal 2.00 work to be performed by the National Park Service and this off prior to the initiation of construction of the White House swin pool. Attached at Tab B is a list of guidelines to be used in the solicitation and acceptance of contributions for the pool. Enclosures CC: Phil Buchen FORD : QERALD LIBRARY TAB A 1. Form fund raising group (group Chairman, Treasurer). 2. Complete pool design (Ron Dixon, NCP). 3. Update earlier NEPA review (Elmer Atkins, NCP). 4. Transmit pool design, together with NEPA review, to the Commission on Fine Arts for its approval (Atkins). 5. Draft financial commitment letter from fund raising group to NPF (group Chairman, Treasurer). 6. Clear funding and informational materials with NPF (Casselman, W/H). 7. Draft construction permit from NPS to NPF (Robbins, Interior). 8. Let construction and A/E contracts (Bryant, NPF). FORD is OERALD LIBRARY TAB B The National Park Foundation (NPF) is a charitable, non-profit corporation established by law to accept and administer gifts in connection with the activities and services of the National Park Service (NPS). NPF has agreed to use its good offices to assist in the construction of a swimming pool on the White House grounds for the benefit of the President of the United States, his family and guests. By resolution of its Board of Trustees, NPF has agreed to accept public donations to the extent necessary to complete construction of the pool, and to make a full and public accounting of the use of all funds received for the project. With regard to the acceptance of donations for this project, the following guidelines are to be observed: 1. The maximum donation permitted is $1,000 from any one person. 2. All donations shall be by check made out to the "National Park Foundation, White House Swimming Pool Fund." 3. No donations of equipment or services will be accepted. 4. No donations from any corporation or union will be accepted. 5. No Federal funds or institutional funds of NPF will be expended in connection with the project. 6. Contributions in excess of those required to complete the project will go to other NPF projects. 7. All contributions to NPF are tax deductible to the extent outlined in the attached letter dated December 31, 1970, from the Internal Revenue Service to NPF. FORD is OERALD LIBRARY US Treasury Department Internal Revenue Service Washington, DC 20224 Date: In reply refer to: DEC 3 1 1970 T:I:I:1:1 National Park Foundation Washington, D. C. 20240 Gentlemen: This is in reply to a letter dated September 3, 1970, submitted by Mr. Bernard R. Mayer, requesting'a ruling that you qualify as an organization described in sections 170(b)(1)(A)(v) and 170(b) (1) (A) (vi) of the Internal Revenue Code so that contributions made to you are subject to the limitations provided by section 170(b)(1)(A) as amended by the Tax Reform Act of 1969. The information submitted indicates that you were established as a charitable corporation to encourage private gifts of property or income therefrom for the benefit of the National Park Service, its activities, or its services. You would thereby further the conservation of natural, scenic, historic, scientific, educational, inspirational, or recreational resources for future generations of Americans. You were established by Public Law 90-209, 81 Stat. 656. Section 8 of the Act provides in relevant part: "Contributions, gifts, and other transfers made to or for the use of the Foundation shall be regarded as contributions, gifts, or transfers to or for the use of the United States." It is the Congressional intent that, while the National Park Foundation is a private corporation, it should be treated as an instrumentality of the United States for the purpose of all tax laws. Senate Report No. 532, Ninetieth Congress; House Report No. 623, Ninetieth Congress. Section 2 of the Act provides that your Board consist of no less than eight members including; the Secretary of the Interior, FOND the Director of the National Park Service, ex officio, and no less than six private citizens of the United States appointed by the Secretary of the Interior. Libanny -2- National Park Foundation The Foundation has perpetual succession with all the usual powers and obligations of a corporation acting as a trustee, including the power to sue and to be sued in its own name. The Act creating the Foundation specifies that the United States is not to be held liable for any debts, defaults, acts, or omissions of the Foundation. Within certain limitations as provided by the Act you are authorized to accept, receive, solicit, hold, administer, and use any gifts, devises, or bequests, either absolutely or in trust, of real or personal property or any income therefrom or other interest therein for the benefit of or in connection with, the National Park Service, its activities, or its services. Section 170 of the Code provides for the deduction of charitable contributions, as defined in section 170(c), payment of which is made within the taxable year, subject to the limitations provided in section 170(b). Section 170(c) (1) of the Code defines a charitable contribution, in part, as meaning a contribution or gift to or for the use of the United States, but only if such contri- bution or gift is made for exclusively public purposes. We conclude that contributions made to you are charitable contributions within the meaning of section 170(c) (1) of the Code, and are deductible by donors in computing their taxable income in the manner and to the extent provided in section 170(b) of the Code. Under section 170(b)(1)(A) of the Code an individual is allowed an additional deduction of an amount not exceeding 10 percent of his adjusted gross income for contributions made to certain organizations, including an organization described in section 170(b)(1)(A)(v) of the Code in the taxable years beginning after December 31, 1963, and beginning before January 1, 1970. Section 170(b) (1) (A) (v) of the Code describes a governmental unit referred to in section 170(c)(1) of the C de. GERALD .001 -3- National Park Foundation Section 170(b) (1) (A) of the Code was amended by the Tax Reform Act of 1969 to provide that for the taxable years beginning after December 31, 1969, an individual is allowed a deduction to the extent that the aggregate of his contributions made to organizations described in section 170(b)(1)(A) does not exceed 50 percent of his contribution base. Contribution base is defined as adjusted gross income (computed without regard to any net operating loss carry- back to the taxable year under section 172). We conclude, based upon the evidence presented, that you are an organization described in section 170(b)(1)(A)(v) of the Code. Accordingly, the additional 10 percent limitation provided in section 170(b) (1) (A) of the Code is applicable to contributions made to you by individual donors in the taxable year to which that percentage is applicable. The 50 percent limitation provided in section 170(b)(1)(A) of the Code, as amended by the Tax Reform Act of 1969, is applicable to contributions made to you in the taxable years beginning after December 31, 1969. Since we hold that you are an organization described in section 170(b)(1)(A)(v) of the Code, it is not deemed necessary to consider whether you qualify as an organization described in section 170(b)(1)(A)(vi) of the Code. Sincerely yours, Lester n. Utter Chief, Individual Income Tax Branch BERALD rono SIBRARY I = Thursday 5/15/75 1:35 Had a call from a private citizen asking where she could make a small donation to the Swimming Pool for the President. Casselman advised the check should be made to National Park Foundation, White House Swimming Pool Committee and mailed to the White House Swimming Pool Committee Washington, D. C. 20500 Jack Stiles would have known -- but he was unavailable. FORD & LIBRARY 07V839 Some items in this folder were not digitized because it contains copyrighted materials. Please contact the Gerald R. Ford Presidential Library for access to these materials. PREDE LIBRARY THURSDAY, MAY 15, 1975 D1, PENNSYLY A Swimming Pool for the South Lawn POOL By Sarah Booth Conroy The first indication that Mr. Ford Plans then called for a covered pool, urged him to proceed with the AREA had decided to go ahead with the with the cost estimated at $300,000. project. President Ford is going to get a pool, first under consideration last Mr. Ford turned down the idea be- The arrival of "swimming pool White House swimming pool after all fall but subsequently abandoned be- cause, as an aide put it then, "The weather," according to Speakes, may and, according to aides, should be cause of the economy, came yesterday have played some part in the Presi- swimming in it by July 1. when reporters noticed excavation in President can't ask people to con dent's decision to go ahead. Construction got under way yester- progress on the South Lawn. tribute to his pool when they re cut- Donations will be handled by A.J. day on the South Lawn for the 22-by- Nessen said $10,000 had already ting down on their groceries." Sehorn of Hayward, Calif. vice chair- 54.83 foot pool, which is expected to been raised for the project, of which Pointing out that the White House man of the U.S. Olympic swimming cost $52,417, plus $9,000 for land- $4,000 was collected by the National physician believes swimming is im- Committee, and William J. Schuiling, scaping. Swimming Pool Institute from its portant to Mr. Ford's health, Nessen a Washington banker who is chairman Presidential Press Secretary Ron members, $5,000 from at group of said yesterday that the pool will be of the Financial General Shareholders Nessen said the outdoor pool will be Olympic swimmers and coaches and available to future Presidents and Inc., a holding company for the First paid for by donations limited to $1,000 $1,000 from small contributions. their families. National Bank of Washington Schui- NEW YORK TIMES - Fri. , May 16, 1975 Gifts to Ford's Swimming Pool Tax Free By WALLACE TURNER Special to The New York Times Lost Estimate Spars SAN FRANCISCO, May 15- Mr. Stiles said that he moved President Ford's swimming Mr. Markert said in a tele- to Washington to be near Mr. pool on the Wiite House phone interview today that he Ford after Mrs. Ford was hospi- grounds will be built with tax- had proposed that the insti talized for cancer surgery. free contributions channeled tute's 1,700 members lead a He said that he learned of through the National Parks fund campaign to build a swim- the problems with the neel'st NEW YORK TIMES - Fri. , May 16, 1975 Gifts to Ford's Swimming Pool Tax Free By WALLACE TURNER Special to The New York Times Goolfile SAN FRANCISCO, May 15 Lost Estimate Soars President Ford's swimming Mr. Stiles said that be moved Mr. Markert said in a tele pool on the Wiite House to Washington to be near Mr. phone interview today than hel grounds will be built with tax- had proposed that thes insti- Ford after Mrs. Ford was hospi- free contributions channeled talized for cancer surgery. tute's 1,700 members lead 2 through the National Parks He said that: he learned of fund campaign to build a swim- Foundation. ming pool for Vice Presidential the problems with the pooi's This will have the effect of use. However. President Nixo cost, as it was first planned,¹ tapping the THE WHITE HOUSE WASHINGTON May 12, 1975 MEMORANDUM FOR: JACK MARSH FROM: BILL CASSELMAN BR SUBJECT: Swimming Pool Per your request, attached at Tab A is a checklist of legal and other work to be performed by the National Park Service and this office prior to the initiation of construction of the White House swimming pool. Attached at Tab B is a list of guidelines to be used in the solicitation and acceptance of contributions for the pool. Enclosures cc: Phil Buchen TAB A 1. Form fund raising group (group Chairman, Treasurer). 2. Complete pool design (Ron Dixon, NCP). 3. Update earlier NEPA review (Elmer Atkins, NCP). 4. Transmit pool design, together with NEPA review, to the Commission on Fine Arts for its approval (Atkins). 5. Draft financial commitment letter from fund raising group to NPF (group Chairman, Treasurer). 6. Clear funding and informational materials with NPF (Casselman, W/H). 7. Draft construction permit from NPS to NPF (Robbins, Interior). 8. Let construction and A/E contracts (Bryant, NPF). TAB B The National Park Foundation (NPF) is a charitable, non-profit corporation established by law to accept and administer gifts in connection with the activities and services of the National Park Service (NPS). NPF has agreed to use its good offices to assist in the construction of a swimming pool on the White House grounds for the benefit of the President of the United States, his family and guests. By resolution of its Board of Trustees, NPF has agreed to accept public donations to the extent necessary to complete construction of the pool, and to make a full and public accounting of the use of all funds received for the project. With regard to the acceptance of donations for this project, the following guidelines are to be observed: 1. The maximum donation permitted is $1,000 from any one person. 2. All donations shall be by check made out to the "National Park Foundation, White House Swimming Pool Fund. " 3. No donations of equipment or services will be accepted. 4. No donations from any corporation or union will be accepted. 5. No Federal funds or institutional funds of NPF will be expended in connection with the project. 6. Contributions in excess of those required to complete the project will go to other NPF projects. 7. All contributions to NPF are tax deductible to the extent outlined in the attached letter dated December 31, 1970, from the Internal Revenue Service to NPF. US Treasury Department Internal Revenue Service Washington, DC 20224 Date: In reply refer to: DEC 3 1 1970 T:I:I:1:1 National Park Foundation Washington, D. C. 20240 Gentlemen: This is in reply to a letter dated September 3, 1970, submitted by Mr. Bernard R. Mayer, requesting a ruling that you qualify as an organization described in sections 170(b)(1)(A)(v) and 170(b)(1)(A)(vi) of the Internal Revenue Code so that contributions made to you are subject to the limitations provided by section 170(b)(1)(A) as amended by the Tax Reform Act of 1969. The information submitted indicates that you were established as a charitable corporation to encourage private gifts of property or income therefrom for the benefit of the National Park Service, its activities, or its services. You would thereby further the conservation of natural, scenic, historic, scientific, educational, inspirational, or recreational resources for future generations of Americans. You were established by Public Law 90-209, 81 Stat. 656. Section 8 of the Act provides in relevant part: "Contributions, gifts, and other transfers made to or for the use of the Foundation shall be regarded as contributions, gifts, or transfers to or for the use of the United States." It is the Congressional intent that, while the National Park Foundation is a private corporation, it should be treated as an instrumentality of the United States for the purpose of all tax laws. Senate Report No. 532, Ninetieth Congress; House Report No. 623, Ninetieth Congress. Section 2 of the Act provides that your Board consist of no less than eight members including; the Secretary of the Interior, the Director of the National Park Service, ex officio, and no less than six private citizens of the United States appointed by the Secretary of the Interior. -2- National Park Foundation The Foundation has perpetual succession with all the usual powers and obligations of a corporation acting as a trustee, including the power to sue and to be sued in its own name. The Act creating the Foundation specifies that the United States is not to be held liable for any debts, defaults, acts, or omissions of the Foundation. Within certain limitations as provided by the Act you are authorized to accept, receive, solicit, hold, administer, and use any gifts, devises, or bequests, either absolutely or in trust, of real or personal property or any income therefrom or other interest therein for the benefit of or in connection with, the National Park Service, its activities, or its services. Section 170 of the Code provides for the deduction of charitable contributions, as defined in section 170(c), payment of which is made within the taxable year, subject to the limitations provided in section 170(b). Section 170(c)(1) of the Code defines a charitable contribution, in part, as meaning a contribution or gift to or for the use of the United States, but only if such contri- bution or gift is made for exclusively public purposes. We conclude that contributions made to you are charitable contributions within the meaning of section 170(c)(1) of the Code, and are deductible by donors in computing their taxable income in the manner and to the extent provided in section 170(b) of the Code. Under section 170(b)(1)(A) of the Code an individual is allowed an additional deduction of an amount not exceeding 10 percent of his adjusted gross income for contributions made to certain organizations, including an organization described in section 170(b)(1)(A)(v) of the Code in the taxable years beginning after December 31, 1963, and beginning before January 1, 1970. Section 170(b)(1)(A)(v) of the Code describes a governmental unit referred to in section 170(c)(1) of the C de. -3- National Park Foundation Section 170(b) (1) (A) of the Code was amended by the Tax Reform Act of 1969 to provide that for the taxable years beginning after December 31, 1969, an individual is allowed a deduction to the extent that the aggregate of his contributions made to organizations described in section 170(b)(1)(A) does not exceed 50 percent of his contribution base. Contribution base is defined as adjusted gross income (computed without regard to any net operating loss carry- back to the taxable year under section 172). We conclude, based upon the evidence presented, that you are an organization described in section 170(b)(1)(A)(v) of the Code. Accordingly, the additional 10 percent limitation provided in section 170(b)(1)(A) of the Code is applicable to contributions made to you by individual donors in the taxable year to which that percentage is applicable. The 50 percent limitation provided in section 170(b)(1)(A) of the Code, as amended by the Tax Reform Act of 1969, is applicable to contributions made to you in the taxable years beginning after December 31, 1969. Since we hold that you are an organization described in section 170(b)(1)(A)(v) of the Code, it is not deemed necessary to consider whether you qualify as an organization described in section 170(b)(1)(A)(vi) of the Code. Sincerely yours, Lester n. Utter Chief, Individual Income Tax Branch THE WHITE HOUSE WASHINGTON April 21, 1975 MEMORANDUM FOR: Jack Marsh FROM: Bill Casselman no SUBJECT: Status of Swimming Pool Proposal At the request of the President, Jack Stiles has been working on a revised proposal to construct a White House swimming pool. As you will recall, the previous proposal was dropped last fall because of high cost (approximately $250, 000) and possible adverse political reaction. Basically, the original proposal provided for the pool design, con- struction, and contracting to be undertaken by the National Park Foundation (NPF), a non-profit, tax exempt corporation, established by law to accept gifts in connection with the activities of the National Park Service (NPS). NPS would issue a construction permit to NPF with the necessary environmental impact statement and Fine Arts Commission clearance. NPF would then award the construction contract on a competitive basis and would be responsible for its administration. All construction work would be coordinated from a security standpoint with the Secret Service. Upon completion of the project, title to the pool would be formally accepted by NPF and trans- ferred to NPS, which would administer the gift on behalf of the Government. The original proposal also provided for initial funding and indemnification to be furnished to NPF thru an ad hoc, broad-based fund raising group to be established for that purpose. Any additional funds would be distributed among the 27 sports on the 1976 Olympic program. A strict dollar or value limit on donations from any one source would be imposed. In addition, donors of equipment or services would be prohibited from commercially exploiting their connection with the project. is FORD GERALD LIBRAN, 2 The revised proposal differs in several substantial ways from the one described above. First, the scope of the project has been reduced. In an effort to make the proposal politically acceptable, it was decided that not more than $75,000 would be expended for the total cost of the construction. This would mean the elimination of any dressing or exercise facilities and the use of berms and shrubbery as protective screening in lieu of a climate-controlled, roofed-in pool enclosure. The feasibility of this change is now being studied by Stiles and Gordon Rudd, the contractor who built the pool at the President's home in Alexandria. Second, the contract would be awarded on a sole source basis, presumably to Rudd, This would eliminate the expense and delay involved in com- petitive bids. While NPF is not bound by the usual Federal procurement laws and regulations applicable to Government agencies, the use of such a contract might raise some eyebrows. Third, initial funding and indemnification would be provided thru J. Willard Marriott, using excess discretionary funds from the 1972 Inaugural Com- mittee. This, too, carries some negative political implications because of the association with the previous Administration. However, except in the case of a short-fall in donations, the funds would be used only as an interest free loan. Finally, the loan would be repaid with monies raised from the following sources: (a) Grand Rapids friends of the President, whose fund raising efforts would be headed by Peter Secchia, a mobile home executive in Grand Rapids, (b) the National Swimming Pool Institute and/or other swimming-oriented organizations, and (c) donations sought via public solicitation from an organization to be headed by a well-known fund raiser, perhaps, Al Sehorn, a noted Olympic supporter. In all other respects, the original proposal, including participation by NPF, would remain the same. cc: Phil Buchen Jack Stiles FORD & 038830 LIBRARY THE WHITE HOUSE WASHINGTON June 10, 1975 MEMORANDUM TO: PHIL BUCHEN FROM: RUSS ROURKE R Phil, I understand that one of the pool fund checks that has been submitted, but not yet deposited, is a $1,000 check from Mrs. Nelson "Happy" Rockefeller. Does this not pose the obvious legal problem of a gift by, or in behalf of, a subordinate government official to his superior (even though this is Vice President to President). FYI, Bill Casselman, Jack Stiles and I will be reviewing all of these checks over the course of the next several days. Your guidance on this particular item was requested by JOM. May 17, 1975 To: Jack Stiles From: Eva Daughtrey John Davis called our office today and said that James Piper of Anaheim, California, wants personally to contribute half of the cost of a solar heater for the President's swimming pool. Mr. Davis is in the business of solar heating systems. He would appreciate a call as soon as possible. He wants to talk with you before the plans are finalized, as he feels this would be an application of energy saving. His phone number is 652-7352 Thanks. FORD is B7V LIBRA pool A.J. SPARKS & COMPANY CORPORATE OFFICE 3040 CHARLEVOIX DRIVE S.E. SUITE 280 CENTENNIAL PARK GRAND RAPIOS, MICHIGAN 49506 MARVIN D. STAHL PRESIDENT May 20, 1975 Mr. Philip W. Buchen Legal Counsel The White House Washington, D.C. 20500 Dear Phil: It is in our best interest to have our President and his staff in good health. The enclosed check is for the White House swim- ming pool. Good luck on this project. Warmest personal regard's to you and President Ford. Than FORDO i LIBRA MARVIN D. STAHL 3295 3280 ROGUE RIVER ROAD BELMONT, MICHIGAN 49306 AY Natural Parks Foundation My 200 1975 00 74-17 724 TO THE ORDER OF $200, Two hundred and no/100 DOLLAR UNION BANK MARVIN D. STAHL AND TRUST COMPANY, N.A. GRAND RAPIDS, MICHIGAN 49502 Marrin D. Pall FREDERICK COLOMBO Surmmung pool 1500 NORTH WOOOWARD SUITE 209 birmingham, MICHIGAN 48011 May 20, 1975 Mr. Philip W. Buchen Counsel to the President The White House Washington, D.C. Dear Phil: I am enclosing herewith my check payable to the National Parks Foundation as a contribution toward the construction of the swimming pool now being constructed for President Ford. It is my understanding that this construction program is strictly being subsidized through voluntary contributions and I trust that in making this contribution I will, in a very small way, manifest my great admiration and respect for the great service that the President is giving to our country. With kindest personal regards, I remain, BERALD FORD LIBRARY Sincerely WellCalombs yours, 9-32 720 FREDERICK COLOMBO 2069 ATTORNEY 1500 N. WOODWARD AVENUE SUITE 209 birmingham, MICH. 48011 may20 1975 P AY TO THE ORDER National Packs Frendation $500.10 OF 00 Five hundred and 100 DOLLARS WEST MAPLE-CRANBROOK OFFICE - 57 BLOOMFIELD VILLAGE National Bank of Detroit NB DETROIT, MICHIGAN WILLIAM W. IRWIN 3890 LAKE DRIVE GRAND RAPIDS, MICHIGAN 49506 May 22, 1975 Mr. Philip W. Buchen Executive Offices The White House Washington, D.C. 20500 Dear Phil: I am enclosing herewith a check made out to the National Parks Foundation which is to be used for construction of the swimming pool on White House grounds. It was a real pleasure, Phil, to see you when I was in Washington week before last. We had an unprecedented trip from the standpoint of enjoying it, knowledge secured, etc. Thanks very much, Phil, for your part in making this such an enjoyable trip for us. As you can well imagine, Mary Lou was so enthusiastic about the couple days that we spent there that only now are her feet beginning to come back to the ground. With best Bill regards, William W. Irwin WWI/smc FORD i GERALD LIBRARY Enc. 296 WILLIAM W. IRWIN 3890 LAKE DRIVE, SE. GRAND RAPIDS, MICH. 49506 Day TO THE national Parks Foundation may 23 $1000 = 1975 74-17 724 00 ORDER OF One thousand and 00/100 DOLLARS UNION BANK AND TRUST company, N.A. GRAND RAPIDS, MICHIGAN 49502 William I wan THE WHITE HOUSE WASHINGTON May 23, 1975 Dear Bill: Enclosed are checks representing contributions to the "Swimming Pool Fund" as follows: 1 - Frederick Colombo Attorney 1500 N. Woodward Avenue Birmingham, Michigan Amount: $500.00. 2. - Mr. Marvin D. Stahl 3280 Rogue River Road Belmont, Michigan Amount: $200.00 Both are payable to the National Parks Foundation. I presume the receipt of these checks will be acknowledged by your Committee. I am very proud that you have taken on the worthy task of heading up the drive to raise funds for the White House swimming pool, and I send my best wishes to you for success. Sincerely, Thil Philip W. Buchen Counsel to the President Mr. W. J. Schuiling President Financial General Bank Shares, Inc. Suite - 12th Floor 1701 Pennsylvania Avenue, N. W. Washington, D. C. 20006 BERALD FORD LIBRARY Enclosures FREDERICK COLOMBO 1500 NORTH WOODWARD SUITE 209 BIRMINGHAM, MICHIGAN 48011 May 20, 1975 Mr. Philip W. Buchen Counsel to the President The White House Washington, D.C. Dear Phil: I am enclosing herewith my check payable to the National Parks Foundation as a contribution toward the construction of the swimming pool now being constructed for President Ford. It is my understanding that this construction program is strictly being subsidized through voluntary contributions and I trust that in making this contribution I will, in a very small way, manifest my great admiration and respect for the great service that the President is giving to our country. With kindest personal regards, I remain, Sincerely JuliCalombs yours, FORD & LIBRAR A. J. SPARKS & COMPANY CORPORATE OFFICE 3040 CHARLEVOIX DRIVE S.E. SUITE 280 CENTENNIAL PARK GRAND RAPIDS, MICHIGAN 49506 MARVIN D. STAHL PRESIDENT May 20, 1975 Mr. Philip W. Buchen Legal Counsel The White House Washington, D.C. 20500 Dear Phil: It is in our best interest to have our President and his staff in good health. The enclosed check is for the White House swim- ming pool. Good luck on this project. Warmest personal regards to you and President Ford. Than MDS:ph Enclosure FORD 8A sund W May 25, 1975 THE NEWS AMERICAN Backstairs At White House Swimming Hole For Ford Costs $52,000 By HELEN THOMAS received at the hands of President Ford's staffers. She re- sented the guards put around the hideaway office when she WASHINGTON - (UPI) - President Ford can hardly was sorting through Nixon papers. wait to get into the swimming pool he has ordered built in the She was also being checked in and out of the White backyard of the White House. House. The construction company still is digging the hole for But the Ford aides were acting under court orders and the $52,000 pool, which will be paid for by public subscription they claim there was no intent to make things more difficult. with a limit of $1,000 from any one person. Miss Woods is often seen on the Washington party cir- Ford keeps asking if the concrete has been poured yet, cuit, and there is some question whether she will want to go and his aides tease him by saying that there will be no lining, to California to live. Except for her devotion to the Nixon only water poured into a dirt hole. family, most of her friends are in Washington. food May 28, 1975 Dear Bill: Enclosed is a check in the amount of $1,000 sent by Bill Irwin to the order of National Parks Foundation. His full name and address is as follows: Mr. William W. Irwin 3890 Lake Drive, S.E. Grand Rapids, Mich. 49506 Sincerely, Philip W. Buchen Counsel to the President Mr. W. J. Schuiling President Financial General Bank Shares, Inc. 1701 Pennsylvania Avenue, N. W. Washington, D. C. 20006 Enclosure FORD & LIBRARY May 28, 1975 Dear Bill: Many thanks for the check you sent made payable to the National Parks Foundation to apply on construction of the White House swimming pool. It is much appreciated and I have promptly turned it over to Bill Schmiling who is serving as Chairman of the fund drive. I appreciated your comments about your visit in Washington, and even though I have been here longer, I share Mary Lou's enthusiasm for this fascinating place and the exciting events we are able to enjoy. Warmest pessonal regards to you and Mary Lou from Bunny and me. Sincerely yours, Philip W. Buchen Counsel to the President Mr. William W. Irwin 3890 Lake Drive, S. E. Grand Rapids, Michigan 49506 FORD i LIBRARY- UNION BANK NATIONAL 200 AND OTTAWA ASSOCIATION TRUST N.W., COMPANY Swimp Pool GRAND RAPIDS, MICHIGAN 49502 June 2, 1975 EDWARD J. FREY Chairman Mr. William J, Schuiling President and Chief Executive Officer Financial General Bankshares Inc. 1701 Pennsylvania Ave. N.W. Washington D.C. 20006 Dear Bill: Enclosed are checks payable to the National Parks Foundation for President Ford's swimming pool. These are checks from directors of our bank as well as two or three other checks sent directly to Phil Buchen. Union Bank directors fully support this program and hope that you will be successful in raising the $63,000. Very best Red regards, enclosures FORD i 038470 LIBRAR THE WHITE HOUSE For file WASHINGTON June 10, 1975 MEMORANDUM FOR: R USS ROURKE JACK STILES FROM: BILL CASSELMAN 26 SUBJECT: Swimming Pool Pursuant to our meeting last week, attached are the revised guidelines for acceptance of donations to the swimming pool fund. Enclosure bcc: Phil Buchen FORD is LIBRARY 038400 The National Park Foundation (NPF) is a charitable, non-profit corporation established by law to accept and administer gifts in connection with the activities and services of the National Park Service (NPS). NPF has agreed to use its good offices to assist in the construction of a swimming pool on the White House grounds for the benefit of the President of the United States, his family and guests. By resolution of its Board of Trustees, NPF has specifically agreed to accept public donations to the extent necessary to complete construction of the pool, and to make a full and public accounting of the use of all funds received for the project. With regard to the acceptance of donations for this project, the following guidelines are to be observed: 1. The maximum cash donation which may be accepted from any one person is $1,000; the term "person" shall include tax exempt organizations as described in Section 501(c)(3) of the Internal Revenue Code (see attached text). 2. All cash donations shall be by check payable to the "National Park Foundation, White House Swimming Pool Fund" or similarly described payee. 3. Donations of equipment or services may be accepted up to a maximum value of $1, 000. 4. No donations from any commercial corporation or other business entity, or any labor organization, shall be accepted. 5. No Federal funds or institutional funds of NPF shall be accepted or expended in connection with the project. 6. Contributions in excess of those required to complete the project may be donated by NPF to NPS to be utilized in the administration of the White House and its grounds. 7. All contributions to NPF are tax deductible to the extent outlined in the attached letter dated December 31, 1970, from the Internal Revenue Service to NPF. FORD § 501 INCOME TAXES Ch. 1 Editorial Notes Section 504, relating to denial of exemption was repealed by Pub.L. 91-172, Title 1, $ 101 (j) (15), Dec. 30, 1969, 83 Stat. 527. § 501. Exemption from tax on corporations, certain trusts, etc. (a) Exemption from taxation.-An organization described in subsection (c) or (d) or section 401(a) shall be exempt from taxation under this subtitle unless such exemption is denied under section 502 or 503. (b) Tax on unrelated business income and certain other activities.-An organization exempt from taxation under subsection (a) shall be subject to tax to the extent provided in parts II and III of this subchapter, but (notwithstanding parts II and III of this subchapter) shall be considered an organization exempt from income taxes for the purpose of any law which refers to organizations exempt from income taxes. (c) List of exempt organizations.-The following organizations are re- ferred to in subsection (a): (1) Corporations 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 corporations are exempt from Federal income taxes. (2) Corporations organized for the exclusive purpose of holding title to property, collecting income therefrom, and turning over the entire amount thereof, less expenses, to an organization which itself is exempt under this section. (3) Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of any candidate for public office. (4) Civic leagues or organizations not organized for profit but operat- ed 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 RD recreational purposes. (5) Labor, agricultural, or horticultural organizations. BERALD LIBRARY (6) Business leagues, chambers of commerce, real-estate boards, boards of trade, or professional football leagues (whether or not administering a pension fund for football players), not organized for 398 US Treasury Department Internal Revenue Service Washington, DC 20224 Date: in reply refer. to: DEC 3.1 1970 T:I:I:1.1 STATEMENT National Park Foundation Washington, D. C. 20240 Centlemen: This is in reply to a letter dated September 3, 1970, submitted by Mr. Bernard R. Mayer, requesting a ruling that you qualify as an organization described in sections 170(b)(1)(A)(v) and 170(b)(1) (A) (vi) of the Internal Revenue Code so that contributions made to you are subject to the limitations provided by section 170(b)(1) (A) as amended by the Tax Reform Act of 1969. The information submitted indicates that you were established as 2 charitable corporation to encourage private gifts of property or income therefrom for the benefit of the National Park Service, its activities, or its services. You would thereby further the conservation of natural, scenic, historic, scientific, educational, inspirational, or recreational resources for future generations of Americans. You were established by Public Law 90-209, 81 Stat. 656. Section 8 of the Act provides in relevant part: "Contributions, gifts, and other transfers made to or for the use of the Foundation shall be regarded as contributions, gifts, or transfers to or for the use of the United States." It is the Congressional intent that, while the National Park Foundation is a private corporation, it should be treated as an instrumentality of the United States for the purpose of all tax laws. Senate Report No. 532, Ninetieth Congress; House Report No. 623, Ninetieth Congress. Section 2 of the Act provides that your Board consist of no less than eight members including; the Secretary of the Interior, the Director of the National Park Service, ex officio, and no less than six private citizens of the United States appointed by the Secretary of the Interior. SERALD -2- National Park Foundation The Foundation has perpetual succession with all the usual powers and obligations of a corporation acting as a trustee, including the power to sue and to be sued in its own name. The Act creating the Foundation specifies that the United States is not to be held liable for any debts, defaults, acts, or omissions of the Foundation. Within certain limitations as provided by the Act you are authorized to accept, receive, solicit, hold, administer, and use any gifts, devises, or bequests, either absolutely or in trust, of real or personal property or any income therefrom or other interest therein for the benefit of or in connection with, the National Park Service, its activities, or its services. Section 170 of the Code provides for the deduction of charitable contributions, as defined in section 170(c), payment of which is made within the taxable year, subject to the limitations provided in section 170(b). Section 170(c) (1) of the Code defines a charitable contribution, in part, as meaning a contribution or gift to or for the use of the United States, but only if such contri- bution or gift is made for exclusively public purposes. We conclude that contributions made to you are charitable contributions within the meaning of section 170(c)(1) of the Code, and are deductible by donors in computing their taxable income in the manner and to the extent provided in section 170(b) of the Code. Under section 170(b)(1) (A) of the Code an individual is allowed an additional deduction of an amount not exceeding 10 percent of his adjusted gross income for contributions made to certain organizations, including an organization described in section 170(b)(1)(A)(v) of the Code in the taxable years beginning after December 31, 1963, and beginning before January 1, 1970. Section 170(b)(1)(A)(v) of the Code describes a governmental unit referred to in section 170(c)(1) of the C de. GERALE FORD -3- National Park Foundation Section 170(b) (1) (A) of the Code was amended by the Tax Reform Act of 1969 to provide that for the taxable years beginning after December 31, 1969, an individual is allowed a deduction to the extent that the aggregate of his contributions made to organizations described in section 170(b)(1)(A) does not exceed 50 percent of his contribution base. Contribution base is defined as adjusted gross income (computed without regard to any net operating loss carry- back to the taxable year under section 172). We conclude, based upon the evidence presented, that you are an organization described in section 170(b)(1)(A)(v) of the Code. Accordingly, the additional 10 percent limitation provided in section 170(b)(1)(A) of the Code is applicable to contributions made to you by individual donors in the taxable year to which that percentage is applicable. The 50 percent limitation provided in section 170(b)(1)(A) of the Code, as amended by the Tax Reform Act of 1969, is applicable to contributions made to you in the taxable years beginning after December 31, 1969. Since Ha hold that you are an organization described in section 170(b)(1)(A)(v) of the Code, it is not deemed necessary to consider whether you qualify as an organization described in section 170(b)(1)(A)(vi) of the Code. Sincerely yours, Lester n. Utter Chief, Individual Income Tax Branch GERALD FORD THE WHITE HOUSE WASHINGTON June 10, 1975 MEMORANDUM FOR: RUSS ROURKE JACK STILES FROM: BILL CASSELMAN 20 SUBJECT: Swimming Pool Pursuant to our meeting last week, attached are the revised guidelines for acceptance of donations to the swimming pool fund. Enclosure bcc: Phil Buchen FORD & LIBRARY 07V835 The National Park Foundation (NPF) is a charitable, non-profit corporation established by law to accept and administer gifts in connection with the activities and services of the National Park Service (NPS). NPF has agreed to use its good offices to assist in the construction of a swimming pool on the White House grounds for the benefit of the President of the United Statës, his family and guests. By resolution of its Board of Trustees, NPF has specifically agreed to accept public donations to the extent necessary to complete construction of the pool, and to make a full and public accounting of the use of all funds received for the project. guidelines are to be observed: With regard to the acceptance of donations for this project, the following 1. The maximum cash donation which may be accepted from any one person is $1, 000; the term "person" shall include tax exempt organizations as described in Section 501(c)(3) of the Internal Revenue Code (see attached text). 2. All cash donations shall be by check payable to the "National described payee. Park Foundation, White House Swimming Pool Fund" or similarly 3. Donations of equipment or services may be accepted up to a maximum value of $1, 000. 4. No donations from any. commercial corporation or other business entity, or any labor organization, shall be accepted. 5. No Federal funds or institutional funds of NPF shall be accepted or expended in connection with the project. 6. Contributions in excess of those required to complete the project may be donated by NPF to NPS to be utilized in the administration of the White House and its grounds. 7. All contributions to NPF are tax deductible to the extent outlined in the attached letter dated December 31, 1970, from the Internal Revenue Service to NPF. LIBRARY GERALD FORD § 501 INCOME TAXES Ch. 1 Editorial Notes Section 504, relating to denial of exemption was repealed by Pub.L. 91-172, Title 1, $ 101 (j) (15). Dec. 30. 1969, 83 Stat. 527. § 501. Exemption from tax on corporations, certain trusts, etc. (a) Exemption from taxation.-An organization described in subsection (c) or (d) or section 401(a) shall be exempt from taxation under this subtitle unless such exemption is denied under section 502 or 503. (b) Tax on unrelated business income and certain other activities.-An organization exempt from taxation under subsection (a) shall be subject to tax to the extent provided in parts II and III of this subchapter, but (notwithstanding parts II and III of this subchapter) shall be considered an organization exempt from income taxes for the purpose of any law which refers to organizations exempt from income taxes. (c) List of exempt organizations.-The following organizations are re- ferred to in subsection (a): (1) Corporations 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 corporations are exempt from Federal income taxes. (2) Corporations organized for the exclusive purpose of holding title to property, collecting income therefrom, and turning over the entire amount thereof, less expenses, to an organization which itself is exempt under this section. (3) Corporations, and any community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual, no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of any candidate for public office. (4) Civic leagues or organizations not organized for profit but operat- ed 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. (5) Labor, agricultural, or horticultural organizations. (6) Business leagues, chambers of commerce, real-estate boards, boards of trade, or professional football leagues (whether or not administering a pension fund for football players), not organized for OF 398 US Treasury Departmen Internal Revenue Service Washington, DC 20224 Date: In reply relee. to: DEC 3.1 1970 T:I:I:1.1 National Park Foundation Washington, D. C. 20240 Centlemen: This is in reply to a letter dated September 3, 1970, submitted by Mr. Bernard R. Mayer, requesting'a ruling that you qualify as an organization described in sections (b) (1) (v) and 170(b)(1) (A) (vi) of the Internal Revenue Code so that contributions made to you are subject to the limitations provided by section 170(b)(1)(A) as amended by the Tax Reform Act of 1969. The information submitted indicates that you ware established as 2 charitable corporation to encourage private gifts of property or income therefrom for the banefit of the National Park Service, its activities, or its services. You would thereby further the conservation of natural, scenic, historic, scientific, educational, inspirational, or recreational resources for future generations of Americans. You were established by Public Law 90-209, 81 Stat. 656. Section 8 of the Act provides in relevant part: "Contributions, gifts, and other transfers made to or for the use of the Foundation shall be regarded as contributions, gifts, or transfers to or for the use of the United States." It is the Congressional intent that, while the National Park Foundation is 2 private corporation, it should be treated as an instrumentality of the United States for the purpose of all tax laws. Senate Report No. 532, Ninetieth Congress; House Report No. 623, Ninetieth Congress. Section 2 of the Act provides that your Board consist of no less than eight members including; the Secretary of the Interior, the Director of the National Park Service, ex officio, and no less than six private citizens of the United States appointed by the Secretary of the Interior. GERALD FORD -2- National Park Foundation The Foundation has perpetual succession with 277 the usual powers and obligations of a corporation acting as a trustee, including the power to sua and to be sued in its own name. The Act creating the Foundation specifies that the United States is not to be held liable for any debts, defaults, acts, or omissions of the Foundation. Within certain limitations as provided by the Act you are authorized to accept, receive, solicit, hold, administer, and use any gifts, devises, or bequests, either absolutely or in trust, of real or personal property or any income therefrom or other interest therein for the benefit of or in connection with, the National Park Service, its activities, or its services. Section 170 of the Code provides for the deduction of charitable contributions, as defined in section 170(c), payment of which is made within the taxable year, subject to the limitations provided in section 170(b). Section 170(c) (1) of the Code defines a charitable contribution, in part, as meaning 2 contribution or gift to or for the use of the United States, but only if such contri- bution or gift is made for exclusively public purposes. We conclude that contributions made to you are charitable contributions within the meaning of section 170(c)(1) of the Code, and are deductible by donors in computing their taxable income in the manner and to the extent provided in section 170(b) of the Code. Under section 170(b)(1)(A) of the Code an individual is allowed an additional deduction of an amount not exceeding 10 percent of his adjusted gross income for contributions made to certain organizations, including an organization described in section 170(b)(1)(A)(v) of the Code in the taxable years 1970. beginning after December 31, 1963, and beginning before January 1, Section 170(b)(1)(A)(v) of the Code describes a governmental unit referred to in section 170(c)(1) of the C de. LIBRARY GERALD P. FORD -3- National Park Foundation Section 170(b) (1) (A) of the Code was amended by the Tax Reform Act of 1969 to provide that for the taxable years beginning after December 31, 1969, an individual is allowed a deduction to the extent that the aggregate of his contributions made to organizations described in section 170(b)(1)(A) does not exceed 50 percent of his contribution base. Contribution base is defined as adjusted gross income (computed without regard to any net operating loss carry- back to the taxable year under section 172). We conclude, based upon the evidence presented, that you are an organization described in section 170(b)(1)(A)(v) of the Code. Accordingly, the additional 10 percent limitation provided in section 170(b) (1) (A) of the Code is applicable to contributions made to you by individual donors in the taxable year to which that percentage is applicable. The 50 percent limitation provided in section 170(b)(1) (A) of the Code, as amended by the Tax Reform Act of 1969, is applicable to contributions made to you in the taxable years beginning after December 31, 1969. Since Ha hold that you are an organization described in section 170(b)(1)(A)(v) of the Code, it is not deemed necessary to consider whether you qualify as an organization described in section 170(b)(1)(A)(vi) of the Code. Sincerely yours, Lester H. Utter Chief, Individual Income Tax Branch R.FORD GERALD ANVISIT , Des aSwimming Poop" file. Wednesday 6/11/75 7:00 Checked with Barry on the $1,000 check from "Happy" Rockefeller. He said Casselman has already discussed this with Rourke and Stiles and they all agreed to return the check. There is a Federal statute which prohibits gifts from subordinate officials to their superiors and, while this may not specifically exclude wives, clearly the spirit of the statute does. FORD is LIBRARY 079835 Wednesday 6/11/75 7:00 Checked with Barry on the $1,000 check from "Happy" Rockefeller. He said Casselman has already discussed this with Rourke and Stiles and they all agreed to return the check. There is at Federal statute which prohibits gifts from subordinate officials to their superiors and, while this may not specifically exclude wives, clearly the spirit of the statute does. FORD & GERALD LIBRARY THE WHITE HOUSE WASHINGTON June 10, 1975 MEMORANDUM TO: PHIL BUCHEN FROM: RUSS ROURKE R Phil, I understand that one of the pool fund checks that has been submitted, but not yet deposited, is a $1,000 check from Mrs. Nelson "Happy" Rockefeller. Does this not pose the obvious legal problem of a gift by, or in behalf of, a subordinate government official to his superior (even though this is Vice President to President). FYI, Bill Casselman, Jack Stiles and I will be reviewing all of these checks over the course of the next several days. Your guidance on this particular item was requested by JOM. FORD Swinning pool UNION BANK AND TRUST COMPANY Drey Edward NATIONAL ASSOCIATION 200 OTTAWA N.W., GRAND RAPIDS, MICHIGAN 49502 EDWARD ]. FREY June 12, 1975 Chairman Mr. Philip Buchen The White House Washington, D.C. 20500 Dear Phil: Enclosed is another check for Jerry Ford's swimming pool. We would like to know how this fund drive campaign is going. Very best Rod Segards, EJF: 1w enclosure FORD is PERALD LIBRAR CHARLES R. EVENSON 1024 2112 ROBINSON RD., S.E. 74-17 ORDER PAY TO OF THE nate Parks Foundation 6/9 GRAND RAPIDS, MICH. 49506 1975 724 $250 00 100 two Hundred Fifty and Too 00 / DOLLARS UNION BANK AND TRUST COMPANY, N.A. GRAND RAPIDS. MICHIGAN 49502 MEMO FORD is G7V1 LIBK Swimming Pool. THE WHITE HOUSE WASHINGTON June 17, 1975 Dear Bill: Here's another check for the National Parks Foundation in the amount of $250 to be used for the swimming pool at the White House. The check is from Charles R. Evenson at 2112 Robinson Road, S. E., Grand Rapids, Michigan, 49506. Ed Frey was the one who sent it on to me and he said he would like to know how the fund drive is going. Therefore, I would appreciate your calling Ed on this point. Sincerely yours, The Philip W. Buchen Counsel to the President Mr. W. J. Schuiling President Financial General Bank Shares, Inc. 1701 Pennsylvania Avenue, N. W. Washington, D. C. 20006 Enclosure LIBRARY GERALD ? FORD 1024 CHARLES R. EVENSON 2112 ROBINSON RD., S.E. 74-17 ORDER TO OF THE nate Parks Foundation 6/9 GRAND RAPIDS, MICH. 49506 1975 724 PAY $250 TOO 00 two Hundred Fafty and Too 00 / DOLLARS UNION BANK AND TRUST company, N.A. GRAND RAPIDS. MICHIGAN 49502 Charl Evensor MEMO UNION BANK AND TRUST COMPANY NATIONAL ASSOCIATION 200 OTTAWA N.W., GRAND RAPIDS, MICHIGAN 49502 EDWARD J. FREY June 12, 1975 Chairman Mr. Philip Buchen The White House Washington, D.C. 20500 Dear Phil: Enclosed is another check for Jerry Ford's swimming pool. We would like to know how this fund drive campaign is going. Very best Rod regards, EJF:1w enclosure t Address GERALD THE WHITE HOUSE WASHINGTON December 8, 1975 MEMORANDUM FOR: RON NESSEN FROM: PHIL BUCHEN T.W.B. SUBJECT: White House Pool Photo Referencing your request to Dick Cheney for advice on the use of a photo of the White House swimming pool in Rudd's new swimming pool catalogue, I recommend that they not be allowed to use this photo. It is my understanding that Jack Stiles indicated to all commercial donors when they made their contributions that it would not be possible to use photos of the pool in connection with advertising campaigns. To grant approval in this case would be inconsistent with this previous decision and would too closely resemble a White House endorsement of the Rudd firm's work. FOND GERALD LIBRARY MEMORANDUM THE WHITE HOUSE WASHINGTON November 24, 1975 MEMORANDUM FOR: PHIL BUCHEN FROM: DICK CHENEY D Attached is a request from the people who built the swimming pool. They would like to use a picture of it in their brochure. Please handle this matter directly with Ron Nessen. Thanks. Attachment FORD is DERALT LIBRARY Rudd's SWIMMING POOL SUPPLY CO., INC. 5145 DUKE STREET POOL ALEXANDRIA, VIRGINIA 22304 Phone 751-3100 TITUTE November 17, 1975 Mr. Ron Nessen The White House 1600 Pennsylvania Avenue Washington, D.C. Subject: White House Pool Photo Dear Ron: Please find enclosed a photo of the White House swimming pool. This is a request for your approval to use this photo on our 1976 Rudd's Swimming Pool Supply Catalog. The printing will be 20,000. We propose to work in the theme of 1776-1976 Bicentennial, color red, white, and blue. Gordon and I want to thank you for all the cooperation you and your people have extended to us. Thanking you in advance. Very truly yours, RUDD'S SWIMMING POOL SUPPLY CO., INC. Rund K.M. Rudd GERALD LIBRARY Swimming Pool Tuesday 2/24/76 2:15 Adolph Kiefer called to say that while Mr. Rumsfeld was here he had asked Mr. Kiefer to assist in the swimming pool -- covers for the pool, etc. He is a former neighbor of his in Northfield, Ill. National Chairman of the Boy Scouts for Aquatics. He did not do any work on the pool but a lot of his friends did. * He would very much to see the pool. He is presently on the research staff in sports advertising of Sears. I checked with Rex Scouten's office (Betty Hogue) 2650 and she said very few people are allowed to see the pool and Mr. Scouten would have to take him there. (If Mr. Buchen said he should do it, she would check with him.) I checked with Mr. Rumsfeld's office (Lee Goodell) and she checked with Mr. Rumsfeld and called me back late this afternoon and said Mr. Rumsfeld and he said "definitely do it - - he's an olympic champ and he's a very fine man." * contributed equipment 3:00 Kiefer had called from the Red Cross Headquarters and 857-3701 said I could reach him there if we had an answer. (Burnside's office) When I called back he had gone. He had called earlier from the Washington Hilton but 234-9700 was not at that number when I tried. (pay phone) Callel the Washington Hilton and they have no one 483-3000 registered there by that name. Called Adolph Kiefer's residence in Northfield; there was no answer. BERALD FORD (312) 446-8866 Not at Hay Adams 638-2260 347-3000 Not at the Mayflower Wednesday 2/25/76 Wednesday 2/25/76 8:55 Reached Mr. Pfeifer's home; he is staying at a Holiday Inn but they don't know which one. He is here with the Boy Scouts Convention. Called Boy Scouts of America and they indicate 530-9360 the convention is being held at the Washington Hilton. Called the Washington Hilton and they will try to 483-3000 reach Mr. Pfeifer (talked with someone at the convention). 9:10 Called Rex Scouten and he will arrange for a visit to the swimming pool if we approve it. Would prefer some time before 1 o'clock (as they have two affairs going on at the same time) -- or tomorrow. But if neither is convenient, they can squeeze him in. 9:20 Mr. Pfeifer called back; he can be over here in five minutes; Mr. Scouten will clear him at the Northwest gate and take him to see the pool. (Phone booth 234-9776 (Pfeifer said he had seen Mr. Rumsfeld at breakfast this morning and Rumsfeld told him if he had any problem to call his secretary and she would get him in.) FORD is GERALD LIBRARY