FEDERAL ELECTION COMMISSION

I Q K Sr, I W ,

THIS IS THE EBiD OF V'UR K) __ FEDERAL ELECTION COMMISSION

I25 K ' IRE1 I NW WASHINGI()N,)(. 2(.l.1,,

June 15, 1978

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. C. M. Millsap Millsap' s 123 East High Street Jefferson City, MO 65101

Re: MUR 553(78) Dear Mr. Millsap:

On June 13 , 1978, the Federal Election Commission found no reasonable cause to believe that Millsap's has violated 2 U.S.C. § 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Committee, although the contribu- tion was made on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth N for Senator Committee.

If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039.

Sin erely,

William C. Oldaker General Counsel

Enclosures

cc: Danforth for Senator Committee Senator John C. Danforth 0 S

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 553(78) Creative Marketing Company ) MUR Lebanon Motor Sales ) Millsap's

CERTIFICATION

Federal Election I, Marjorie W. Emmons, Secretary to the

13 , 1978, the Commission, do hereby certify that on June to adopt the recommendation Commission determined by a vote of 5-0 actions in the of the General Counsel to take the followinq

above-captioned matter: that 1. Find no reasonable cause to believe

Creative Marketing Company, Lebanon Motor §441b(a). Sales, and Millsap's violated 2 U.S.C. the General 2. Send the draft letters attached to

Counsel's Report dated June 7 , 1978.

3. Close the file in this matter. Commissioner Tiernan was not present at the time of the vote.

_- Marj e W. Emmons Secr ary to the Commission

Received in Office Of Commission Secretary: 6-8-78, 3:42 Circulated on 43 hour vote basis: 6-9-78, 12:00 0 0

BEFORE THE FEDERAL ELECTION COMMISSION

June 7 , 1978

In th,. Matter of ) Creative Marketing Company ) MUR 553(78) Lebanon Motor Sales ) Mills-ap' s GENERAL COUNSEL'S REPORT

1. Summary of allegations and Commission action

During its examination of the records kept by the Danforth for Senate Committee ("the Committee"), the Audit Division discovered apparent evidence of corporate contributions having been made to and accepted by the Committee in seeming violation of 2 U.S.C. § 441b(a) . Three of these contributions, in the forms of checks from Creative Marketing Company, Lebanon Motor

Sales, and Millsap's, were in the sum of $100 or more.

On April 25, 1978, the Commission found reason to believe that

Cr ative Marketing Comnany, Lebanon Motor Sales, and Millsap's had violated Section 441b(a) by making corporate contributions to the

Committee. Because of evidence given the Audit Division concerning the Committee's efforts to screen out corporate contributions, the

Commission found no reason to believe that the Committee had knowingly accepted corporate contributions. Letters were sent to the three apparent corporate contributors informing them of the

Comission 's findings.

Evi dlonce

On May 2, 1973, the Office of General Counsel received a

letter from Mr. Eugene Smith of Lebanon Motor Sales stating that he is an individual doing business under the name of Lebanon Motor Sales and that he has never done business as a corporation. 0 ~-2-

He pointed out that at the same time his contribution was made to the Committee there existed a corporation in the same city by the name of Lebanon Motor Sales, hence the existence of possible c,'Alusion on the part of the Office of the Secretary of State of

M :;souri.

On May 8, 1978, the Commission received a response from

Mr. C.M. Millsap stating that Millsap's is a partnership owned by him and his wife. He further explained that Millsap's had once been incorporated but that entity is defunct and was dissolved in 1960.

The Commission sent a letter to Creative Mar -eting Company which was returned unclaime.,ed from City, , dated

May 16, 1978. A follow-up telephone call to the Office of the

Secretary of State revealed that Creative Marketinc Compan,' was not an incorporated entity at the time the contribution was made.

It appears that the Secretary of State's Office confused this particular companv with a corooration of the same name in a different city.

Re c me nd at ion

1. Find no reasonable cause to believe that Creative Marketinc

Company, Lebanon MIotor Sales, and Millsap's violated 2 U.S.C. §44!b(a).

2. Send attached letter.

3. Close the file.

j4 / __- J 'i:4 Datd William C. Oldaker General Counsel 0 9

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. C. M. Millsap illsap' s 123 East HIigh Street Jefferson City, MO 65101 Re: M3R 553(78) Dear -r. Millsap: On June , 1978, the Federal Election Commission found no reasonable cause to believe that Millsap's has violated 2 U.s.c. 5 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Comrittee, although the contribu- tion was amde on a business check. Enclosed for your information is a copy of the ceneral Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will Le included in the public disclosure fib& of the Danfortlh for Senator Committee. If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039. Sincerely,

William C. Oldaker Generel Counsel Enclosures cc: Danforth for Senator Committee Senator John C. Danforth S S

~'FEDERAL ELECTION COMMISSION

1 25 K ';IR1l I NV WA..\H IN( , () I 1 2() 4(0 1

June 15, 1978

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. Eugene Smith Lebanon Motor Sales 411 East Commercial Lebanon, MO 65536

Re: MUR 553(78)

Dear Mr. Smith:

On June13 , 1978, the Federal Election Commission found no reasonable cause to believe that Lebanon Motor Sales has violated 2 U.S.C. § 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Committee, although the contribution was made on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth for Senator Committee.

If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039. Since\rely,

William C. Oldaker General Counsel

Enclosures

cc: Danforth for Senator Committee Senator John C. Danforth 0 0

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) Creative Marketing Company ) MUR 553(78) Lebanon Motor Sales Millsap's

CERTIFICATION

I, Marjorie W. Emmons, Secretary to the Federal Election the Commission, do hereby certify that on June 13 , 1978, recommendation Commission determined by a vote of 5-0 to adopt the in the of the General Counsel to take the following actions above-captioned matter:

1. Find no reasonable cause to believe that

Creative Marketing Company, Lebanon Motor

Sales, and Millsap's violated 2 U.S.C. §441b(a).

2. Send the draft letters attached to the General

Counsel's Report dated June 7 , 1978.

3. Close the file in this matter. Commissioner Tiernan was not present at the time of the vote. 6% -Marj r/e W. Emmons Secr -ary to the Commission

Received in Office of Commission Secretary: 6-3-73, 3:a2 Circulated on 48 hour vote basis: 6-9-73, 12:00 0 0

BEFORE THE FEDERAL ELECTION COMMISSION

June 7 , 1978

In the Matter of ) ) Creative Markt-ting Company ) MUR 553(78) Lebanon Motor ':ales Millsap' s GENERAL COUNSEL'S REPORT

1. Summary of allegations and Commission action

During its examination of the records kept by the Danforth

for Senate Committee ("the Committee"), the Audit Division

discovered apparent evidence of corporate contributions having been made to and accepted by the Committee in seeming violation

of 2 U.S.C. § 441b(a) . Three of these contributions, in the

forms of checks from Creative Marketing Company, [,hl-inon Motor

Sales, and Millsap's, were in the sum of $100 or mroro.

On Ar ril 25, 1978, the Commission found reason to believe that

Cre;1tive Marketing Company, Lebanon Motor Sales, and Millsap's had

violated Section 441b(a) by makinq corporate contributions to the

Committee. Because of evidence given the Audit Division concerning

the Committee's efforts to screen out corporate contributions, the

Commission found no reason to believe that the Committee had

knowinqglv acceDted corporate contributions. Letters were sent to

the three apparent corporate contributors informing them of the

Commission's findings.

Evidence

On May 2, 1978, the Office of General Counsel received a

letter from Mr. Eugene Smith of Lebanon Motor Sales stating that

he is an individual doing business under the name of Lebanon

Motor Sales and that he has never done business as a corporation. -2-

He pointed out that at the same time his contribution was made

to the Committee there existed a corporation in the same city by the name of Lebanon Motor Sales, hence the exi:;tence of possible confusion on the part of the Office of the Secret,Lir! of State of

Missouri.

On May 8, 1978, the Commission received a response from

Mr. C.M. Millsap stating that Millsap's is a partnership owned

by him and his wife. He further explained that Millsap's had once

been incorporated but that entity is defunct and was dissolved

in 1960.

The Commission sent a letter to Creative Marketing Company

wich was returned unclaimed from Kansas City, Mi-souri, dated

Maw 16, 1973. A follow-u-p telep;hone call to the Office of te-,

Secretary. of State revealed that Creative Marketin Company was

not an incorporated entit, at the time the contribution was made.

It anears that the Secretary of State's Office confused this

particular company with a corporation of the same name in a

different city.

Recoenat ion

1. Find no reasonable cause to believe that Creative Marketing

Company, Lebanon M1otor Sales, and Millsap's violated 2 U.S.C. §44!b(a). 2. Send attached letter.

3. Close the file.

Date William C. Oldaker General Counsel 0 0

CERTIFIED MAIL RETURU -RECEIPT REQUESTED Mr. Eugene Smith Lebanon Motor Sales 411 East Comercial Lebanon, MO 65536 Re: MR 553(78) Dear Mr. Smith:

On June , 1978, the Federal Election Covuuission found no reasonable cause to believe that Lebanon Motor Sales has violated 2 U.S.C. S 441b(a) in that this entity was not a corporation at the time it contributed to the Dan6orti for Senator Committee, although the contributi~n was aaie on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These docunents plus a copy of this letter will be include, in the public disclosure file of the Danforth for Senator Cornittee.

If yoo'ave any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4U39.

Since rely,

William C. Oldaker General Cousel Enclosures cc: Danforth for Senator Committee Senator John C. Danforth FEDERAL ELECTION COMMISSION

\\ . Ik'HI ) I )\2\4\

June 15, 1978

CERTIFII ED MAIL RETURN RECEIPT REQUESTED

Mr. Max Walters Creative Marketing Company 900 Washington Street Kansas City, MO 64105 Re: MUR 553(78)

Dear Mr. Walters:

On June 13, 1978, the Federal Election Commission found no reasonable cause to believe that Creative Marketing Company has violated 2 U.S.C. § 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Committee, although the contribution was made on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth for Senator Committee.

If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039.

Since ely,

William C. Oldaker General Counsel

Enclosures cc: Danforth for Senator Committee Senator John C. Danforth 0 0

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) MUR 553(78) Creative Marketing Company ) Lebanon Motor Sales ) Milisap's

CERTIFICATION

the Federal Election I, Marjorie W. Emmons, Secretary to June 13 , 1978, the Commission, do hereby certify that on 5-0 to adopt the recommendation Commission determined by a vote of following actions in the of the General Counsel to take the

above-captioned matter: that 1. Find no reasonable cause to believe Motor Creative Marketing Company, Lebanon §441b(a). Sales, and Millsap's violated 2 U.S.C. to the General 2. Send the draft letters attached 1978. Counsel's Report dated June 7 ,

3. Close the file in this matter. the vote. Commissioner Tiernan was not present at the time of

Marj e W. Emmons Secr ary to the Commission

Received in Office of CoTmission Secretary: 6-8-78, 3:42 12:00 Circulated on 48 hour vote basis: 6-9-78, 0 S

BEFORE THE FEDERAL ELECTION COMMISSION

June 7 , 1978

In the Matter of ) Crative Marketinq Company ) MUR 553(78) I.'-banon Motor Sal(; ) Milisap's GENERAL COUNSEL'S REPORT

1. Summary of allegations and Commission action

During its examination of the records kept by the Danforth

for Senate Committee ("the Committee"), the Audit Division

discovered apparent evidence of corporate contributions having been made to and accepted by the Committee in seeming violation

of 2 U.S.C. § 441b(a) . Three of these contributions, in the

forms of checks from Creative Marketing Company, Lebanon Motor

Sales, and Milisap's, were in the sum of $100 or more.

On An.ril 25, 1978, the Commission found reason to believe that

Creative Marketing Company, Lebanon Motor Sales, and Milisap's had

violated Section 441b(a) by making corporate contributions to the

Committee. Because of evidence given the Audit Division concerning

the Committee's efforts to screen out corporate contributions, the

Commission found no reason to believe that the Committee had

knowingly accepted corporate contributions. Letters were sent to

the three apparent corporate contributors informing them of the

Com.lission's findincs.

Evidence

On %lay 2, 1973, the Office of General Counsel received a

letter from Mr. Eugene Smith of Lebanon Motor Sales stating that

he is an individual doing business under the name of Lebanon

Motor Sales and that he has never done business as a corporation. -2-

He pointed out that at the same time his contribution was made to the Committee there existed a corporation in the same city by the name of Lebanon Motor Sales, hence the e:.:i;tence of possible confusion on the part of the Office of the Secret.,iry of State of

Missouri.

On May 8, 1973, the Commission r-ceived a response from

Mr. C.M. Millsap stating that Millsap's is a partnership owned by him and his wife. He further explained that MilIsap's had once been incorporated but that entity is defunct and was dissolved in 1960.

The Commission sent a letter to Creative Marketing Company which was returned unclaimed 'from 'Ka nsas City, Missouri, dated

Maw 16, 1978. A follow-un telephone call to the Office of the

Secretary of State revealed that Creative Marketing Company was not an incorporated entity at the time the contribution was made.

It appears that the Secretary of State's Office confused this particular company with a corporation of the same name in a different city.

Reco-=me n1 at ion

1. Find no reasonable cause to believe that Creative Marketina

Company, Lebanon MIotor Sales, and Millsap's violated 2 U.S.C. 5441b(a). 2. Send attached letter.

3. Close the file.

DatJ William C. Oldaker General Counsel 0

CERTIFIED MAIL REUR REEI-P ES 'ED Mr. Max Walters Creative Marketing Ccmapany 900 Washington Street Kansas City, MO 64105 Re: MUR 553(78) Dear PT. Walters: On June , 1978, the Federal Election Commission found no reasonable cause to believe that Cre&tive Marketing Company has violated 2 U.S.C. S 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Committee, although the contributi*9 was made on a business check. Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Comission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth for Senator Cccuittee. If you have any questions, please contact Anne A. vWeissenborn, the attorney assigned bo this matter, at (202) 523-4039. Sincerely,

William C. Oldaker General Counsel Enclosures cc: Danforth for Senator Committee Senator John C. Danforth BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

Creative Marketing Company ) MUR 553(78) Lebanon Motor Sales Millsap's

CERTIFICATION

I, Marjorie W. Emmons, Secretary to the Federal Election

Commission, do hereby certify that on June 13 , 1978, the

Commission determined by a vote of 5-0 to adopt the recommendation of the General Counsel to take the following actions in the above-captioned matter:

1. Find no reasonable cause to beli(,ve that

Creative Marketing Company, Lebanon Motor

Sales, and Millsap's violated 2 1.S.C. §441b(a).

2. Send the draft letters attached to the General

Counsel's Report dated June 7 , 1978.

3. Close the file in this matter. Commissioner Tiernan was not present at the time of the vote.

ate Maj W. Emmons Secr ary to the Commission

Received in Office of Commission Secretary: 6-8-78, 3:42 Circulated on 48 hour vote basis: 6-9-78, 12:00 0

June 8, 1978

4EMORANDUM TO: Marge Eumons FROM: Elissa T. Garr SUBJECT: MUR 553 Please have the attached General Counsel's on HUR 553 distributed Report to the Commission on a 48 hour tally basis.

Thank you. BEFORE THE FEDERAL ELECTION COMMISSION

June 7 , 1978

In the Matter of

Creative. Marketing Company ) MUR Th3(78) Lebanon Motor Sales Millsap' s GENERAL COUNSEL'S REPOWT

1. Summary of allegations and Commission action

During its examination of the records kept by the Danforth

for Senate Committee ("the Committee"), the Audit Division

discovered apparent evidence of corporate contributions having

been made to and accepted by the Committee in seeming violation

of 2 U.S.C. § 441b(a) . Three of these contributions, in the

forms of checks from Creative Marketing Company, Lebanon Motor

Sales, and Millsap's, were in the sum of $100 or more.

On April 25, 1978, the Commission found reason to believe that

Creative Marketing Company, Lebanon Motor Sales, and Millsap's had

violated Section 441b(a) by making corporate contributions to the

Committee. Because of evidence given the Audit Division concerning

the Committee's efforts to screen out corporate contributions, the

Commission found no reason to believe that the Committee had

knowingly accepted corporate contributions. Letters were sent to

the three apparent corporate contributors informing them of the

Commission's findings.

Evidence

On May 2, 1978, the Office of General Counsel received a

letter from Mr. Eugene Smith of Lebanon Motor Sales stating that he is an individual doing business under the name of Lebanon

Motor Sales and that he has never done business as a corporation. -2-

He pointed out that at the same time his contribution was made

to the Committee there existed a corporation in the same city by the name of Lebanon Motor Sales, hence the existence of possible confusion on the part of the Office of the Secrett'ry of State of

Missouri.

On May 8, 1978, the Commission received a r(-,:snse from

Mr. C.M. Millsap stating that Millsap's is a partnurship owned by him and his wife. He further explained that Milisap's had once been incorporated but that entity is defunct and was dissolved in 1960.

The Commission sent a letter to Creative 'arketing Company which was returned unclaimed from Kansas City, Missouri, dated

May 16, 1978. A follow-up telephone call to the Office of the

Secretary of State revealed that Creative Marketing Company was not an incorporated entity at the time the contribution was made.

It appears that the Secretary of State's Office confused this particular company with a corporation of the same name in a different city.

Recommendation

1. Find no reasonable cause to believe that Creative Marketingi

Company, Lebanon M1otor Sales, and Millsap's violated 2 U.S.C. §441b(a).

2. Send attached letter.

3. Close the file. ~/ 7 4,; 4< Date . William C. Oldaker General Counsel SFEDERAL ELECT!ON COMMISSION

-125 K "dSI I I NW W\%H\~IN( I ) ()t. 20.

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. Eugene Smith Lebanon Motor Sales 411 East Commercial Lebanon, MO 65536 Re: MUR 553(78)

Dear Mr. Smith:

On June , 1978, the Federal Election Commission found no reasonable cause to believe that Lebanon Motor Sales has violated 2 U.S.C. § 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Committee, although the contribution was made on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth for Senator Comittee.

If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039. Sincerely,

William C. Oldaker General Counsel

Enclosures

cc: Danforth for Senator Committee Senator John C. Danforth FEI)ERAL ELECTION COMMISSION

' Iki I I N.WA

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. Max Walters Creative Marketing Company 900 Washington Street Kansas City, MO 64105

Re: MUR 553(78)

Dear Mr. Walters:

On June , 1978, the Federal Election Commission found no reasonable cause to believe that Creative Marketing Company has violated 2 U.S.C. § 441b(a) in that this entity was not a corporation at the time it contributed to the Danforth for Senator Committee, although the contribution was made on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth for Senator Committee.

If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039.

Sincerely,

William C. Oldaker General Counsel

Enclosures

cc: Danforth for Senator Committee Senator John C. Danforth It N

' FEDERAL ELECTION COMMISSION

I 25 K SI R[ I NW. WASHING ION,1) C. 20()

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. C. M. Millsap Millsap' s 123 East High Street Jefferson City, MO 65101

Re: MUR 553(78)

Dear Mr. Millsap:

On June , 1978, the Federal Election Commission found no reasonable cause to believe that Millsap's has violated 2 U.S.C. § 441b(a) in that this entity was not a coriporation at the time it contributed to the Danforth for Senator Committee, although the contribu- tion was made on a business check.

Enclosed for your information is a copy of the General Counsel's Report on MUR 553(78), and a copy of the certification of the Commission's determination. These documents plus a copy of this letter will be included in the public disclosure file of the Danforth for Senator Committee.

If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039. Sincerely,

William C. Oldaker General Counsel

Enclosures cc: Danforth for Senator Committee Senator John C. Danforth 0

FUERAl ELECTION COMMISSION

I 2 i K SI Rl II'-A

May 19, 1978

EMAORANDUM T1-. C;HARL ES STE" J FL

1OM.MAR3ORIE W. 'IM(YS.

flAR 553 (7() - Interim Status Reoort dated 5-17-78 Received in OCS: 5-13-78. 10:39

r't cred ,Jc. as ,catd on . ,a u

at 11:39 a.m., May 18, 1978. r'cie itujve*,q Dn.M. . .e.. ons have teen

Ofe >~+-r 3. :he Interim Status m~emort. , N,

May 17, 1978

MEMORANDUM TO: Marge Emons FROM: Elssa T. Garr SUBJECT: MUR 553

Please have the attached Interim Status Report on MUR 553 distributed to the Commission. Thank you.

Ill Ill 0 BEFORE THE FEDERAL ELECTION COMMISSION

May 17, 1978

In the Matter of

Creative Marketing Company ) MUR 553(78) Lebanon Motor Sales & Mii] sap'(;

INTERIM STATUS REPORT

During its examination of the records kept by the Danforth for Senate Committee ("the Committee"), the Audit Division discovered that apparent corporate contributions had been accepted by the Committee in violation of 2 U.S.C. §441b(a).

Three of these contributions, those from Creative Marketing

Company, Lebanon Motor Sales, and Millsap's, were in the sum of

$100 or more.

The Office of the General Counsel determined that while the

Committee had apparently accepted five corporate contributions aggreqating in excess of $100, the evidence given the Audit

Division of the Committee's efforts to screen out corporate contributions warranted a finding of no reason to believe that the

Committee had knowingly accepted contributions from corporations.

On the other hand, a recommendation was made that the Commission find reason to believe that Creative Marketinq Company, Lebanon

Motor Sales, and Millsap's violated §441b(a) by rakinq corporate contributions to the Committee. On April 25, 1978, the Commission approved the above recommendation. -2 -

Letters were sent to the three respondents informing them of the Commission's findings. The Office of the General Counsel has received replies from two of the three business entities involved, each of which denies incorporated status. We are awaiting an answer from the third respondent.

2 William Cf. 1ae Da General Counsel May 2, 1978

Ms. Anne A. Weissenborn office of the General Counsel Federal Election Commission 1325 K Street N.W. Washington, D.C. 20463

Re: MUR 353(78)

Dear Ms. Weissenborn:

My attorney, Thomas J. O'Neil, of Lebanon, Missouri, contacted you by phone on May 1, 1978 regarding the letter that you wrote to me on April 26, 1978. This letter is in response to both your letter of April 26th and the phone conversation that my attorney had with you on May 1st.

The check that I donated to the Danforth for Senator Committee in the amount of $100.00 was written on an account that I had the Commerce Bank of Lebanon under the name of Lebanon Motor at account Sales. However, that bank account was an individual bank of Lebanon and I was an individual doing business under the name Sales. The contribution was not made out of a corporation Motor throuqh checking account. Moreover, T have never done business a corporation.

At approximately the same time as the date of my check, September of J. R. 22, 1-976, an individual in Lebanon, "issouri by the name Holt was connected with a corporation by the name of Lebanon I Sales and perhaps this is where the confusion caTe in. M.otor is operated have never been connected with the corporation which Sales. by vr. J. R. Holt and has the name of Lebanon Motor I would ask If there is anything further regarding this matter, his that you please contact my attorney, Thomas J. O'Neil, at phone address at Adams At Third, Lebanon, Missouri, 65536, number area code 417-532-2101.

Thank you very much. Very truly yours,

-7

Fuqene Smith 411 East Commercial Lebanon, MO 65536 Mr. Eugene Smith 411 E. Commercial Lebanon, MO 65536

Ms. Anne A. Weissenborn Office of the General Counstl Federal Election Comrnission 1325 K Street 4.W. Washington, D.C. 20463 FF"Ay" R:I.EATION VASmss ', I 3tA"432 62 0 U ,- I I C, It.

'178 W1lI PM I:ZZ

6 a

MI' P ~ t~1 F' ~ ~ :ON AQ

;jMAY dP4I~ POSTAGE AND FEES

.. Mr. lax Wa I tors Cr-ati Market ing Compa n, Cr-900K a WashinCi yr ka te - -.--...... Kansas City , ml- o ur 4 0 SENDER ('mplete Items I, 2. and ,. Add yur address in the "RETURN TO" space on reverse,.

The filiiwmig servie is requested (check one). Sh (w to whom and date delivered ...... Show to whom, date, and address of delivery. RESTRICTED DELIVERY Show to whom and date delivered ...... E RESIRICTED DELIVERY, Show to whom, date, and address of delivery. $ _- ()N T'I.T POSTMASTER FOR FEES)

2. ARTICLE AOORESS D TO-

3..ARTICLE DSCRIION: REGISTERED NO NO, INSURED NO.

(Always ,ta!n signature of address** or agent) m _. e-'have received the article described above. SIGNATURE. ' Addrrs,c Au.".thoriz,-da gent

DATEor DELIVERY POSTMARK

5. AODREsS (Complete only f requ"ested)

UNAQL TO DELIVER 1ECAUSE: CLERK'S I " "' INITIALS

GPO 1977--0-234-337 [i DRAL EL ECTION COMMISSION VI¢"K iI.tI " \

A;-.ri.] 26, 1978

CERTIFIED '1:jI, RETI ,. R, " T.. ,,,U TED

I. C. '1. Millsapc -I Mills a-' s 123 . High Street Jefferson City, .Missouri 65101

RtE : 2I 7 R (7S)753

Dear Mr. 1ills:

Ss I- oter inLCr!'7VC U L-- t - deral iI ound re,. to eiDeve, that vi o:1 e the-T Fo cr. 1 ], Lion C.-_n:v,>:

.A C CC 197 1a s ! Is-- ' 1 a o 0O SO1S D ., . 0nour ,t:> ca On)s :iLa±NYisinhn d 2 U. .C. S- 42b . bv hai in, ; Fade a corn:or-at,. 533,. cimeu'o:;t,, o S]'.$ on July 19, 127(. W"e h a,:v numbered,- thi~~s.ms '- .:_, .

LU.qr th]: A~c - 'ouI ave,- n c'"nr t un "Lvtodmn t. no a'ct on should b, inst you..aenca Pleaso sumt. -1arials a. ;ctul o lcal v'shich vou bele v ;-e_ ro 1 e" .';t to the_ Commis ion ' s cons idura t ion of_ t:is. -, to aSorcSrito t 1:,ions51 It:; or s ot ': .. a .. . Cuiunder 1 oath . n(D

~Tho ,",>-m- ssioc:.;, _s under a ,t', t ...4.v, .. . Ua!]'Y:>2 CY .9 21.ba t~ots or u:.1mpln~tion:>; .'nhch vo:u wish :o submi tco th Comhmission '-t-:or sh.. d ] 527 tc wiatir n v roce2iD of~ this n7 -. LI ouW na-

1 -s, 'Sn z- ci I s 0 n C 1 1 - -3Vbor 1 ~~~~~ -'cl at U(0)7 -s~aeSooi - -2-

This matter will remain confidential in accordance with 2 U.S.C. §437g(.:a) (3) (B) unless you not-.iffy the Commission in writ1j tLiat you wish the nvretigation to be made public. iF you intend to be represenced by counsel in this mattei please have such counsel. so notify us in writing.

S iLriccrelv yours,

'illiam C. 1idaser Gc~er iCounsel1

cc: Senator John C. ), I or tla

\ Cq<.EC -1,- 0 SENDP.R ("lmpkte itern; 2Al Add our addre,SIn the RETURN TO spae rev,e rw . rj

I The tollmhn . sr\ o i stt..d ( heck mi-) 3-- Show to whot;)II d dareli._dj ired 1t"how to Whotm. di(., and addrc-,, of ic,, RI RR(TI. 1) D I.[VIRY hW to whom and date dcliicred RI-" STRi(Til) DItLIVERY Slhov 1i1 uhon, date .attd Iddress of dcl',.crv S C (((I)NS IT P()STMA ITER F()R FI.TS)

2. ARTICLE ADDRESSED TO:

d4,

3. ARTICLE DESCRIPTION: REGISTERED NO, ;TFE NO INSURED NO.

C (Always obtain signature of addressee or agent) -4 I have rect-ived the article described abodc. ,t Sil iAT41 E \ddr, \ 'l l"( (1 ,6,it

z DATE OF DELIVERY POSTMARK M a

5. ADDRESS (Complete only 4f requestedt " .,

-4

6. UNABLE TO DELIVER BECAUSE: CLERK'S INITIALS FEDERAL ELECTION COMMISSION

1 2' K 'sIkI I I %W WAY.\ii%(" 10ON. 1 20l46

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Ir. C. 11. Millsap Millsap' s 123 E. High Street Jeffruson City, Missouri 65101

RE: MUR 553 (78)

Dear Mr. Millsap:

This letter is to n you that the Federal Election Commission has foud reason to believe that your company has violated the Feder:,,1 Election Campagin Act of 1971, as amended ("he Act") Specifically, the Conmm-.ission has found reason to boliev, that vou _- company has violated 2 U.S.C.-§441( by having made a corporate contribution to the Danifort:h for Scn ite Committe in the amount of SIQ0on July 19, 1976. We have number.d t-is matter :4UR 553.

Under the Act ,ou have an opoortunitv to d(monstra -e-- that no action should be taken against you. P1e ase subit any factual or lecal materials which you believe are relevant to the Commission's consideration of this matter. Where ap*:ropriate explanations or statements should be submitted under oath.

The Commission is under a dut- to investieate this matter e:xeditiously. Therefore, an- statemoni-ts or ex:planations which you wish to submit to the Comission withi regard to this matter should be submitted within t:n days of receipt of this notification. If you have eny auestions, pClease contact Anne A. Weissenborn, the attorney assiqned to this matter, at (202)523-4039. -2-

This matter will remain confidential i -Iccordance with 2 U.S.C. §437q(i) (3) (B) unless you nt fy7 the Commission in writ i-n that you wish the i v, ,igation to be made public. IF you intend to be r ,r- :iented by counsel in this matt-r, please have such nmirsel so notify us in writing.

S Lncerely yours,

William C. Oldaker General Counsel cc: Senator John C. Danforth FEDERAL i ECTION COMMISSiON

4 Ae:ril 2(,, V97F3

CERTIFIED MAIL RETJRN RECEIPT REQUP'kSTED

Mr. 11,u ~n( Smnit " Leb)iion Motor Sales 411 E. Comnmercial Lebanon, Missouri 6-536

R: MUR 533(78)

Dear 'r. Smfih:

This 1_ t .r 13 to A 2 o:0... , '.'ou T".,Z _t ...... ',,,ri 01~~~ ~~ J>.L31: 0h ' .?,-D3C0I to your 'o* :;'2.',' i.0s viola ucd th F.

-a Ss-,,1 16 7:ci -c_,t~-zp __ :i < a r ha0 20sl ' C 1 C4o077 ' ns z : t, 7-c .f 7 0 c con r b 1vi to-h . ,, rh o0.- CoL17idI-,e ,. i t<- amou:-ItC17001 o00 i19On 1 on

Undor crot vc0u 1 .:, a .0.oL U CCAiw1 -1mon3S1r:e that no ac:o1 sold ho toho;3 aainst you. P1.'.-0s suDnl' an' 1-1t1 or oal matorin;s wOich y0u i 'e &rI r9'.vt to tho Com:Scission's cn s1 -.ntion1 to- should 10 suoi:,i:t od.dor 0h.

.. i i0 . ss ci ho.ota :s

t•-. c - ' o700,.' 201; 0f th:s :1oti111J0;::.'. :0.2 have -.'''v . -o:3,0 :please co1tact A.:o -, Woissonorn , the

.... nCP2 to 01i1 mo... , :: (231)0 23-.. -2-

This matter wiI remain confidential i ri accordance with 2 U.S.C. §437(J(a) (3) (M) unless you not Iif the Commission in writ i:nq th It y o u w i, sh tiw nv v:;I i g ti to be made public. If you intend to bi.' r, lr,, nted by counsel in this matter .)l -Ise Iha v e Suc ,C(.11Sl so notify us in writing.

Sincere'.VOWio,:;,

WiLliam C. O1cak er General Counsei

cc: Senator John C. D,1nrorL'-

* SENI;' 7FR ',mpletetem Add Your address1. 2.in ,I the "RETURN TO - : , . 7 - *c~c ~ C "..- The i nw s5r;ite is reiluesred ((ht(k onc). 1 diiwhom aInd date de)iveed . .... ,vhmfSh date, and address ct del ivr. 4 R I Y1,R(TI) DELIVERY Show to whom and date delivered, :fl REYSIR( T'[ DELIVERX. Shtowt,, whom (date,and address of dci rs ((ON'1'LT POSTMASTER FOR FEES)

2. ARTICLE ADDESDT

z - /

T 3. ARTICLE DESCRIPTION:- REGISTERED NO. FRTIFIED NO. INSURED NO. V ISR NO M~IE N _ 'A______

INITIALS

.22 GPO 1977 -0-234 FEDERAL ELECTION COMMISSION

IQ' K ',TRII "\,.W ,v. ',I( I ( )(, !40

CERTIFIED MA I L RETURN RECEIPT REQUESTED

Mr. Eugene Smith Lebanon Motor Sales 411 E. Commercial Lebanon, Missouri 65536

RE: MUR 53 3(78)

Dear Mr. Smith:

This letter is to inform you that th' V''cb.ral Election Cormission has found reason to b1 i ,0ethat your companv has violated the Federal Ele:' on Campaign Act of 1971, as amended ("the Act"). Speei fic,11,, the* CoAm.ission has found reason to believe th your compaiy has violated 2 U.S.C.§'4,lIc(a) by having ma,: a corporate contr ibution to the Danf:orth for Senate Committee in the amount of $100 on Seotember 22, 1976. We have numbered this matter- MUD 353.

Under the Act you have an opportunity to demonstrate that no action should be taken agqainst you. Please submit any,- factual or legal materials which you believe are relevant to the Commission's consideraton of this matte. here appropriate explanations or statements s ould be submitted, under oath.

The CoLmission is under a duty to inva-Late this matter exoeditiousy. Therefore, an, stato:nts or e:.: vl nations which you wish to submit to the Com-mission with regard to this matter should be submit ,dwithin ten days of receict of this notif cation. IF '.,ou have ny -u-- ions, contact-lease Anne A. Weiss,nborn, the attorney,, assigned to this matter, at (202)3523-4039. -2-

This matter will remain confidential ii accordance with 2 U.S.C. §437g(a) (3) (1-) unless you not i 1 the Commission Lin writing that you wish fthe inv,,, i jation to be mad,, public. If you intend t-. be r pr,:;l so notify us in writing.

Sincerely yours,

William C. Oldaker General Counsel cc: Senator John C. Danforth FED[RAI ELECTION COMMISSION

\\ O'4xt )\ r( 1 2 6',11, 7 Ar>ril 26, 1978

CERTIE1D M I L RETURN RLCEIPT RiCUESTi D

Mr. *,la:,; Walters Creativ Iar:ct ing Company 900 Waington Strc,<:t Kansas Cit,!, iissouri 64105 RE: 3-! 5 3 !\7) Dear '.1r. 1alters:

c' tter IS to , C ' Lh 1.. ni ...r Li n C sso' as fo rea snnt

hasor cm.auh. .... •S~ Ua'iolCtod l the berlE~ci:aiI "l? '02cin' (0>T ss1o .is~ fou[d re so o(Oli-, ..--

amou - $1 -s, o c7 1c c this :.0att UP 3e"r n. .0

L' doo - tar' Ac t oou a,, c o,_ an.,tn :p:- " t ao ;str~ tha no act ion sOOo1l1 h Ostak-n O 1"a on. s,,:ni: an(.Yicn 'y' ncual or l2a1 mat: iri LS yoo beier<:. are ; iValt to t - Co,,missio.' S CO %S7ourai

o L r'NP,/O.O i.OS or S tromO. tS

s ubit, 'sneer oIar

. Co:onmission .s u1r.,-. u':': to _'te os 1n,,s.

a': . arZL",2::'o',:}si no 1: "* T-o -r o 1: ' , a.'' S(tet '.t s or e:. 19.-o Lio:s vhich '.01. wish to su C-t 1.o t.-0; <1oYmiIssiDI wi1th r. :arj to this :watt.or shouel - bu suhm: it1,.. 'ithin nS --_-'o recoien ofC this o::ioa-.o'l. I: ':ru h3ave --_o L. aj. ' . s<' r n, th ."assnod no his ,atter, at (202) 23-4039. 0 S

-2-

This nmt t er w i,L remna in con1irt i n accordance with 2 U.S.C. I -)7,1 (a) (3) (B) un1ss( 'u nl i V the Comission fin wri i i that you w ,,-,i/,,igations ih to bm made public. If you int(l-ed to be ri,,sencod by coul5;,]_ i. thi s mlIt tor plaso l! such sosoIflcsel nctif, us in writ_ t nq.

S 1 yorc.;o~cu

William C. ,I liar GocraI COull

cc: Senator Joh i, C. Dar forth

' - . ,- C*,-[ . [ S t 1 FEDERAI 1-1 ECTION COMMISSION

I12 5 K IRt II V WAS1) fl%( , k )% 1 2046 1

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. lax Walters Creative Marketinq Company 900 Washington Streelt Kansas Cit'y, Mlissouri 64105 RE: MU) 53 (78) Dear Mr. Walters:

This letter L; to inform you that the Federal Elect-ion ComumissLo.ni has found reason to beli ev t hat your company has violated the Federal ElecL i n Campaqin ACt of 1971, as imendod ("the Act"). Specifi ,all, th Cov'iss ion :as hound reason to be'ieve tht your comoanv has violated 2 U.S.C. 441i(a) byIhaving made ,i corporat contribuLion to tChe Danforth for Sen 'ta Comii ttee in th e amount of $123 on October- 13, 1976. We hav- numbered this matter MUR 333.

Under the Act you have an opportunity to demonstrate that no action should be taken against you. Please submit any! factual or legal materials which you believe are relevant to the CommLission's consideration of this matter. Where appropriate explanations or sta tements Should be submitted under oath.

The Commission is under a duty to invc-t Jat this me.tr ex>di1iousl.. Therefore, an,. 7 statc'Lcmu :s or explanatcons which _''o ish toito t CoImmission with recard to thlis matter should be submitt'.. -, within ten as of receipt of this notification. If you have any questions, please contact Anne A. Weiss2nborn, the attorney assigned to this matter, -. (202)523-4039. -2-

This matter will remain v"onfidential in accordance with 2 U.S.C. §437g(a) (3)(B) inless you notify the Comission in writing that y',i wish the investigation to l-, made public. If you infltnd to be represented by cuUMn:vd in this matter, pleow ; , have such counsel so not]ify us in writing.

.;if)cerely yours,

William C. Oldaker General Counsel cc: Senator John C. Danforth BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of MUR 553 ( /o) Creative Marketinq Company Lebanon Motor Sales Millsap's

CERTIFICATION

I, Marjorie W. Emmons, Secretary to the Federal Election

Commission, do hereby certify that on April 24, 1978, the

Commission approved without objection the recommendations in the

First General Counsel's Report dated April 20, 1978 in the above- captioned matter as follows:

1. Find no reason to believe that the Danforth for Senate Committee knowinaly accepted cornorate contributions in violation of 2 U.S.C. §44lb(a).

2. Find reason to believe that Creative Marketing Comnany, Lebanon "otor Sales, and Millsap's violated 2 U.S.C. S lb(a) by makinq corporate contributions to the anforth for Senate Committee.

3. Send the letters attached to the First General Counsel 's Report

Date: "--',,' ) , !arjorie 1-. Emmon Secretary to the Commission

Renort Dated: 4-20-78 Rece'ved in Office of Commission Secretary: 4-20-78, 3:49 Circulated on 2a hour no-objection basis: 4-21-78, 11:00 I] i)RAI I I C-I ION CO ,11SION

H.',!, K fHIi \

APPI1 24, 1978

MEMORANI)IIM TO: CHARLES STEELE

FROM: MARJORIE EMMONS

RE: GENiERAL COU!iSEL REPORTS ON COMPLIANCE MATTERS

At 11:00 a.m. on Fri day, April 21, 1978, th e Office of the Commission Secretary circulated the General Counsel's Reports on the following MOU S to the Commission:

MUR 495

,UR 536 MUP 527

These docu;ments were circulatedJ on a no-objection basis, and at noon on April 24. 177,, our Wice has received no obiectons to the reco merlations contained in the above-named reports April Z0, 1978

Irmmons MEMORANDUM TO: Marge Llissa T. Garr FROM:

SUBJECT: HUR553 report on MUR 553 attached 7 day Please have the on a 24 hour no-objection the Commission distributed to

-%basis. Thank you.

N FEDERAL ELECTION COMMISSION

1325 K Street, N. W. Washington, D. C. 20463

FIRST GFNERAL COUNSEL'S REPORT

DATE AND TIME OF TRANSMITTAL MUR 4 553 BY OGC TO THE COMMISSION _ '

STAFF Weissenborn

COMPLAINANT'S NAME: Internally generated (Audit). See attached audit memo.

RESPONDENTS' NAMES: Creati-ve Marketing Company; Lebanon Motor Sales; Millsap's

SUM.MARY OF ALLEGATIONS

During its examination of the records kept by the Danforth

for Senate Committee ("the Committee"), the Audit Division

discovered that six apparent corporate contributions; had been accepted by the Committee. (See Audit Memo). The iiking of such

contributions constitutes a violation of 2 U.S.C. j441b(a) on the parts of the corporations involved, while knowing acceptance by

the Committee would also be a violation of Section 441b(a) . Three of these contributions, those from Creative Marketing Company,

Lebanon Motor Sales, and Millsap's, were in the sum of $100 or more. -2-

PRELIMINARY LEGAL ANALYSIS

The audit of the Committee disclosed contributions made by means of checks drawn on the accounts of six business entities. The Office of the Secretairy of State of Missouri confirmed that there were corporat-ions registered

in the names of each of these businesses.

Three of the six checks were in amounts of $100 or more. One of the contributions was refunded on September

28, 1978, thirteen days after receipt, while the remaining

five were refunded on March 17, 1978.

According to the Audit Division, the Committee

attempted to systematically screen out corporate contribu-

tions by contacting questionable contributors by telephone

to ask whether the funds involved in the contribution were

personal or not. The policy was to note t

contact on the back of the appropriate contributor card

and to retain or refund the contribution on the basis of

the contributor's answer. Approximately one half of the

Coimmittee's contributor cards involving contributions

from other than individuals bore such notations concerning

telephone inquiries, includinc; the cards for five of the

six contributions noted above. The one exception

involved the contributor card for Jillsap's.

It is the opinion of the Office of General Counsel

that while it is apparent that the Committee in fact

accepted five corporate contributions aggregating in -3-

excess of $100 which were not immediately returned to the

contributors, the evidence given the Audit Division of the

Committee's efforts to screen out corporate contributions

warrants a finding of no reason to believe thlit the

Committee knowingly aiccepted contributions I t>mi corporations.

We recommend a finding of reason to be l i,,ve that

Creative Marketinq Company, Lebanon Motor S I,:;, and

Millsap's violated 2 u.S.C. §441b(a) by makiwi; corporate

contributions to the Committee.

RECOMMENDATIONS

1. Find no reason to believe that the Danforth for Senate

Committee knowingly accepted corporate contr ibutions in violation of 2 U.S.C. §441b(a).

2. Find reason to believe that Creative Markdting Company,

Lebanon Motor Sales, and Millsap's violated ' U.S.C. §441b(a) by making corporate contributions to the Dan torth for

Senate Committee.

3. Send attached letters. AUDIT MEMO

FEDiRAI ELECTION COMMlIlSSION

)%( 2M c),;!h M~arch 131 1979 ME MC R AND!p m

TO: Wl l. 1 AMII OLDA K'ER

T HR 0 U H ORLA ND0 B. POTTER P F-C Tr) 60 STAFF oDTE FRMP0 1 0B 0 j A/; IC HAL TER SU JEC-. D, l KYI, H FOR S KJATOR CO "-1I[Tr E -_ POSS I. CORPORATE CO ITB TIO

Durinr t h e 'dt of the Danfnrth it was no te t h ,a for -Senator Comi ttee, Six (6) contriLvjions from six ate cce-,ted The an7>ro-)ri by the Committee (see ttachment I). S) tU; a r tary of State vPrife " the co rc h 1 97e ro rate

TH e n -I,V US t the oll v;ed owino nrocedure t 0 isr- that corporate Contri butions were a cc ec: a con tri bution wa- not- received from b (i.e. > iiness other than an or partnershi ) th e contributor CC n taC P by, telphnne was w 0t, and queried as to the source U on (i e. corporate o the wjas fite or personal fun ds). The acc0)ted he responsecontrib tiie or rejectd based unn t given. 0 n Yarh , 1972 w recommended that the co ntrbut the Commr i ttee refund ions noted above. The Commit checs shojld be tee stated that the nailed by Tuesdav March di- Sra:f will be furnished lM., 1978, and retund ':"cK with a c In addition the Committee oDV of each etter and b r', Ca nceid checks will furnish co ies of bank: s (front and ba unon e:. n t receipt of their

is referred to as a O0 your office for considera tion Pick, Ha tar on ex If you have any questions, PIease tension 3-4155. contact

Att-ch-en as stated A -7-C

ATTACHMENT

SCHEDULE OF POSSIBLE CORPORATE CONTRIBUTIONS

DATE OF CONTR I BUF)R DATE OF NAMIE OF ENTITY C HE C K AN0 UN T I COPPO RAT!0il

Creati v/f 1arketi n Co .I 10/18/70 $126.00 Di(nne . Davis/ Delozier Real ty 9/7/76 25.00 5122/64 Econ o my Pro d u c t s Co. 10/29/76 25.00 The P.D. George ** Co. 9/15/76 50.00 6/1/21 Lebanon 1,o to r I Sa es 9/ 2 6 100.00 9/7/76 1 s a s ) 7 / 19/ 76 100.00 1 /? / 57 TOr 7 , S425. 00

i ssotri Co r Po r a ti o r i1469O - inic orporated Feb ru a ry 1971. Co rporate Ca rter forfe ited, but not revokLed, 1 975 for t4. .anua:-v 1 non-fil inq of 1971 repo-"

Jrded Sep tember 28, 1976 by Co9ittee. (all others refunded March 17, 1 978) FEDERAL El ECTION COMMISSION

CERTIFIED MAIL RETURN RECEIPT REQUESTED

Mr. C. M. Millsap Millsap's 123 E. High Street Jefferson City, Missouri 65101

RE: MUR 553 (78)

Dear Mr. MillsaQ:

This letter is to inform you that the Federal Election Commission has found reason to believe that your company has violated the Federal Election Camp agin Act of 1971, as amended ("the Act"). Specifically, the Conmission has found reason to believe that your company has violated 2 U.S.C. 544b(a) b-y having made a corporate contribution to the Danforth for Senate Comrmittee in the amount of $100on July 19, 1976. We have numbered this matter "4UR 532.

Under the Act you have an opportunity to demonstrate that no action should be taken against you. Please submit any factual or legal materials which you believe are relevant to the Corunission' s consideration of this matter. Where appropriate explanations or statements should be submitted under oath.

The Commission is under a duty to investigate this matter exeditiously. Therefore, anz statements or explanations which you wish to submit to the Commission With regard to this matter should be submitted within ten days of receipt of this notification. If you have any cuestions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202)323-4039. -2-

This matter will remain confidential in accordance with 2 U.S.C. §437g(a) (3)(B) unless you not ify the Commission in writinq that you wish the inve:;tigation to be made public. If you intend to be r(.-presented by counsel in this matter, please have such counsel so notify us in writing.

Sincerely yours,

William C. Oldaker General Counsel cc: Senator John C. Danforth ( FLI[ARAI EIECTION COMMISSION H t" ' , Ik~ III N W

T AV 1 f% 'I'I I \ I ( O

CERTIFIED IMAIL RETURN RECEIPT Ri:LQU)(ESTED

Mr. M1ax Walters Creative Marketing Company 900 Washinqton Street Kansas Cit%, Missouri 64105 RE: MUR 553 (78 Dear Mr. Waiters:

This letter is to inform you that the I',:!' ral Tlecion C,,,mission has found reason to beli( v,, that_- your companv.: has violated the Federal Electio.1 (ampagi, Act of 1971, as amended ("the Act"). Specific: livy,,the Commission has found reason to believe "at vuiir comnanv has violated 2 U.S.C. §44b(a) by having made icorpor. contribution to the Danforth for Senate Coumifrtee in the amount of S512 on October 13, 1976. We have numbered tis ma tat :UR 532.

Under the Act you have an opcortunity to demonstrate that no action should be taken against you. Please submit any factual or leqal materials which you believe are relovanz to the Commission's consideration of this mater. Where appropriate explanations or statements should be submitted under oath.

The Co mission is under a duty to investigate this matr_ ex,-di_ _ious l,. Therefore, a,. statements or explanations which you wish to submit to the Co1Mmission with regard to this matter should be submi-'ted1 within ten days o receip of this notification. If you have any questions, please contact Anne A. Weissenborn, the attore ~ ~assigned to this matter, at (202)523-4039. -2-

This matter wi I I remain confidential it) iccordance with 2 U.S.C. §437,1(,) (3) (B) unless you nor i fy tile Commission in writl ii that you wish the inv'.:;tigation to be made public. If you intend to be rcprusented by counsel in this mat t.er, please have. such counsel so notify us in writing.

Sincerely yours,

William C. Oldaker General Counsel cc: Senator John C. Danforth 0 0

FEDERAL EI ECTION COMMISSION

(i 2046

CERTIFIED MAIL RETURN RECEIPT REQw:S;TED

Mr. Eugene Smith Lebanon Motor Sales 411 E. Commercial Lebanon, Missouri 65536

RE: MUR 553 (78)

Dear Mr. Smith:

This letter is to inform you that the V ,daral Election Commission has found reason to bel iuv,- that your comnany has violated the Federal Elect ion Campai_-'n Ac - of 1971, as amended ("the Act"). Spec fi:lll, tiv, Co:is s ion has found reason to believe thai Jour comnam! has violated 2 U.S.C. §44b(a) by having mado a corporate contribution to the Danforth for Senate Comm.raitee in thue amount o. $100 on September 22, 1976. We have numbered this matter MUR 532.

Under the Act you have an opportunity to demonstrate that no action should be taken against you. Please submit an"....factual or legal materials which you believe are relevant to the Commission's consideration of this matter. Where appropriate explanations or statements should be submitted under oath.

The Comission is under a duty to inv(,stigate tils matter e :xtepitious . Therefore, any staLuments or e xl-aations which you wish to submit to the Commnission with. recard to this matter should be submitted within ten das of recoipt of this notification. If you have any questions, please contact Anne A. Weissenborn, the attorney assigned to this matter, at (202) 523-4039. -2-

This matter will remain confidential in accordance with 2 U.S.C. §437g(a) (3) (B) unless you notifjy the Commission in writing that you wish the inv,:;tigation to be made public. If you intend to be repw,:;ented by counsel in this matter, please have such coniin:ol so notify us in writing.

Sincerily yours,

William C. Oldaker General Counsel cc: Senator John C. I)nforth BEFORE THE FEDERAL ELECTION COMMISSION

In the Mf:jtter of

Creative: Marketing Company MIJR 553 (78) Lebanon Motor Sales Millsap's2

CERTIFIA'ATION

I, Marjorie W. Emmons, Se(uretary of the Federal Election

Commission, do hereby certify that on April 1978, the

Commission adopted the recommendations of the General Counsel as follow:

I. Find no reason to believe that the [)anf'orth for Senate Conmittee knowingly accepted corporate contributions in violation of-. 2 U.S.C. §441b(a).

2. Find reason to believe that Creative Marketing Company, Lebanon ",otor Sales, and Millsap's violated 2 U.S.C. 544lb(a) by making corporate contributions to the Danforth for Senate Committee.

3. Send attached letters. /I- k)5 0

FEDERAl ELECTION COMMISSION

V ,4 iI I( )", 20 1.4 , March 13, 1979 MEMC PAN DI)M

TO: WILLIAM OLDAKER

THROUGH: ORLANDO B. POTTER STAFF DIRECTOR FROM: ' 6OBCOSTA/RICK HALTERP"

SUBJECT: DANFORTH FOR SENATOR COMMITTEE - POSSIBLE CORPORATE CONTRIBUTIONS

Durinq the audit of the Danforth for Senator Committee, it was noted that six (6) con tributions from six (6) corporations were accepted by the Committee (see Attachment I). The approoriate Secretary of State verified the corporate status on March 3, 1978.

The Committee informed us that the following procedure was followed to insure that corporate contributions were not accepted: When a contribution was received from other than an individual (i.e. business or partnership) the contributor was contacted by telephone and queried as to the source of the contribution (i.e. corporate or personal funds). The contribution was either accepted or rejected based upon the response given.

On March 9, 1978, we recommended that the Committee refund the contributions noted above. The Committee stated that the refund checks should be mailed by Tuesday, March 14, 1978, and the Audit staff will be furnished with a copy of each letter and refund check. In addition, the Committee will furnish copies of the cancelled checks (front and back) upon receipt of their bank statement.

This matter is referred to your office for consideration as a possible MUR. If you have any questions, please contact Rick Halter on extension 3-4155.

Attachment as stated ATTACHMENT

SCHEDULE OF POSSIBLE CORPORATE CONTRIBUTIONS

DATE OF CONTRIBUTOR DATE OF NAME OF ENTITY CHECK AMOUNT INCORPORATION Creative Marketi ng Co. * 10/18/76 $125.00

Dianne L. Davis/ Delozier Realty 9/7/76 25.00 5/22/64

Economy Products Co. 10/29/76 25.00 4/17/58

The P.D. George Co.** 9/15/76 50.00 6/1/21

Lebanon Motor Sa I es 9/22/76 100.00 9/7/76

Mi 11 sap' s 7/19/76 100.00 1/2/57

TOTAL S425.00

* t1i ssouri Corporation -146390 - incorporated February 9, 1971. Corporate Cha rter forfei ted, but not revoked, January I , 1975 for non-f ii ng of 1974 reports.

** Refunded September 28, 1976 by Committee. FEDERAl EI.ECTION COMMISSION

1,25 K S IRIlI I % W

THIS IS THE BEGIlNJII.G OF IThR P