September 22, 2003 Commissioner Mark W. Everson Internal Revenue Service 1111 Constitution Avenue, NW Washington, D.C. 20224 Dear Commissioner Everson: We are writing to request that the Internal Revenue Service examine the tax-exempt status of Greenpeace Fund, Inc., a non-profit corporation chartered under Section 501(c)(3) as an educational organization. As documented in the accompanying report, Greenpeace Fund, Inc., knowingly and consistently violates the letter and spirit of the law. Instead of operating "exclusively for . educational purpose," as is required of 501(c)(3) organizations, Greenpeace Fund, Inc., clearly functions as a vehicle for the laundering of tax-deductible contributions. During a three-year span, Greenpeace Fund, Inc., diverted over $24 million in tax-deductible contributions to related entities for use in non-qualifying programs. Generally designated as for "general support," rather than for a specific and measurable qualifying, i.e., educational, program, Greenpeace Fund, Inc., distributed: $3.8 million to Greenpeace, Inc., in 1998; $4 million to Greenpeace International and other affiliates in 1998; $4.25 million to Greenpeace, Inc., in 1999; $3.8 million to Greenpeace International and other affiliates in 1999; $4.5 million to Greenpeace, Inc., in 2000; $3.7 million to Greenpeace International in 2000; and $0.8 million to Greenpeace affiliates in foreign countries in 2000. Greenpeace, Inc., is incorporated as a 501(c)(4) organization, meaning that it is free to conduct advocacy-related program activities. But by definition, such activities do not qualify under 501(c)(3), which calls into question Greenpeace Fund, Inc.'s, practice of providing funding to Greenpeace, Inc. Examples of activities conducted by Greenpeace, Inc., and Greenpeace International that do not qualify under 501(c)(3) include: Blockading a naval base in protest of the war in Iraq; Boarding an oil tanker for a "banner hang"; Breaking into the central control building of a nuclear power station; and Padlocking the gates of a government research facility. To divert tax-deductible contributions for use in programs that clearly do not qualify under 501(c)(3) is to mislead donors and violate the letter and spirit of the law. Greenpeace Fund, Inc., cannot be allowed to continue its deceptive practice and both benefit from tax-deductible contributions and fund advocacy program activities. We therefore urge the Internal Revenue Service to put and end to this practice and take appropriate action to bring Greenpeace Fund, Inc., into compliance with the law. Thank you for your attention to this matter. Sincerely, Michael Hardiman Executive Director Public Interest Watch 1425 P Street, NW Suite 706 Washington, DC 20005 How to Contribute