By Matt Corley
August 17, 2017

Freedom Frontier, a politically active nonprofit, admitted raising more than $1 million in 2015 after initially telling the IRS it raised no more than $50,000 that year. The admission, which was made in an amended tax return, came a little over a month after Citizens for Responsibility and Ethics in Washington (CREW) reported on inconsistencies between Freedom Frontier’s initial 2015 tax return and Federal Election Commission (FEC) records.

As CREW noted on March 1, Freedom Frontier contributed $250,000 in 2015 to a super PAC supporting Sen. Lindsey Graham’s (R-SC) presidential run, a donation that would have been virtually impossible if the group’s initial tax return was accurate. The amended return, which was signed on April 12, finally acknowledges the $250,000 contribution as well as more than $600,000 in additional spending, mostly for “grassroots advocacy/lobbying.” Freedom Frontier now reports that it raised nearly $1.19 million in 2015,  a more than 2000 percent increase over what the nonprofit initially reported to the IRS.

The giant jump in Freedom Frontier’s reported revenue wasn’t the only new revelation from the amended tax return. The filing also reveals that Freedom Frontier shared a contractor with the super PAC it funded. The nonprofit paid 406 Enterprises $199,377 for “consulting.” The same company was paid $232,404 by Security is Strength PAC in the fall of 2015 for mobile advertising boosting Sen. Graham in the Republican presidential primary.

The super PAC’s last payment to 406 Enterprises was made on November 25, 2015, the date of Freedom Frontier’s $250,000 contribution, which was enough to cover all of the super PAC’s payments to the company. The timing and amount of the payments suggests the contribution from Freedom Frontier may have been earmarked for the super PAC’s mobile ads. Since Freedom Frontier was established as 501(c)(4) social welfare organization, the group is not required to disclose its donors, meaning the ultimate source of the funds is unknown.  

A Node in a Dark Money Network

New information provided by the amended tax return further clarifies the nonprofit’s ties to an infamous dark money network that has injected anonymous money into elections across the country since at least 2010. The network consists of a handful of loosely-connected nonprofits with nondescript names that run ad campaigns attacking political candidates or fund super PACs that do the same, all in an effort to keep donors secret. In addition to financial connections among the organizations, a small group of lawyers, accountants, and political operatives help tie together the various entities. CREW has been tracking this network since 2014.

406 Enterprises, the contractor that created mobile advertising for Security is Strength PAC and also worked for Freedom Frontier, is a good example of how the different parts of the network can interact. 406 Enterprises is run by Tom Norris, an Ohio-based government affairs consultant for the concrete industry, who has been involved with several nonprofits and super PACs that have worked together to use anonymous money to influence elections. Norris is the former president of the Jobs and Progress Fund, as well as the former executive director of the Government Integrity Fund. In 2014, both of those nonprofits contributed tens of thousands of dollars to a federal super PAC called the Hometown Freedom Action Network. The super PAC, in turn, paid 406 Enterprises nearly $450,000 for mobile advertising. The payments to Norris’ firm were often made in close proximity to the contributions from the nonprofits affiliated with him.

In 2016, CREW filed IRS complaints against both the Jobs and Progress Fund and the Government Integrity Fund for acting as political groups while claiming to be 501(c)(4) “social welfare” organizations. Though not the only factor, both groups’ funding of the Hometown Freedom Action Network played a role in the complaints.

Several other individuals revealed on Freedom Frontier’s amended tax return also have ties to nonprofits involved with this network. The filing was prepared by Brad Elgin, an accountant who has worked for both the Jobs and Progress Fund and the Government Integrity Fund. Two of Freedom Frontier’s officers, John Jude and Jim Robey, have ties to another nonprofit, American Policy Coalition, Inc., that donated $2.2 million to super PACs in 2016, including completely funding a super PAC that contributed nearly $1.98 million to the campaign of now-Missouri Gov. Eric Greitens (R). That same year, Freedom Frontier was the sole funder of another super PAC that spent millions on ads attacking Gov. Greitens’ primary opponents.

In addition, Joel Riter, the person listed as Freedom Frontier’s principal officer on its initial 2015 tax return, is a central player in the dark money network of which Freedom Frontier is so clearly a part. He has been listed as the chairman of the Government Integrity Fund and the president of Citizens for a Working America, a nonprofit that has funded both attack ads and super PACs. He is also the treasurer for several federal super PACs, including some funded by nonprofits in which he has held leadership roles.

No Explanation for the Wildly Inaccurate Original Filing Has Been Provided

Freedom Frontier originally filed what is known as Form 990-N, a shortened tax form that small tax-exempt organizations with gross receipts of $50,000 or less can file. The information required on these forms is extremely limited, asking for little more than the organization’s legal name, mailing address, website URL, and a principal officer’s name and address.

Almost all of the information Freedom Frontier reported on its initial form had to be changed on the amended return. For example, Freedom Frontier originally told the IRS its mailing address was in Austin, TX, but later changed it to a post office box in Washington, DC. As noted above, on the 990-N, Riter was listed as Freedom Frontier’s principal officer, but his name doesn’t appear at all on the amended form.

On its amended return, Freedom Frontier did not acknowledge any of the changes it made and did not explain why its initial filing was so incomplete. There was no explanation of why the group initially claimed to have raised $50,000 or less when it actually raised more than $1 million. And there was certainly no effort to clarify why a $250,000 contribution to a super PAC, which had been reported to the FEC, was not disclosed to the IRS until a month after CREW wrote about the discrepancy.