[Ncdxf-bod-sub] FW: [NCDXF-BoD-Sub] Conference Call Postponed

Thu Nov 6 15:10:03 PST 2014

Don, we don't need "legal advice".  Perhaps some need to re-read the C&L
opinion which I, as a lawyer, asked Coopers to issue.  You don't need to
rely on my "old-timer" status.  Just read the C&L opinion which is in drop
box.  It recites the facts that occasioned the opinion,  and they arose in
the context of the Peter I DXpedition.

Next, your repeated claim that "a Mormon Church ruling" is some part of the
basis of the C&L opinion continues to baffle me.  I don't see any reference
to such a ruling in their opinion letter, nor did that subject ever come up
in my correspondence with C&L.  Whatever that "Mormon Church ruling" says
(perhaps you have a reference to the Rev. Rul. Involved), the C&L opinion
was not "based" on it.

Third, the original grant to NCDXF of 501(c ) (3) status also had nothing to
do with any such ruling.  As I have often reported, NCDXF was the brainchild
of an accountant (and former neighbor of mine), Vince, K6KQN (now W6EE), who
saw a method by which tax deductible contributions could be solicited from
others, and to some lesser extent provided by participants, to finance
DXpeditions they would conduct.   Until the Peter I DXpedition, costs were
relatively minimal so the issue of potential limitations on participant
deductions was never an issue.  The need for large participant contributions
to a major travel budget to Peter I made it necessary for us to seek some
independent guidance which we did.

Fourth, the C&L opinion contains conditions and limitations (50%) on
amounts, which limitations we have always observed.  Sadly, the participants
here have not yet agreed to contribute that much.  I will be glad if they do
so.

73, Glenn, W6OTC

From: NCDXF-BoD-Sub [mailto:ncdxf-bod-sub-bounces at kkn.net] On Behalf Of
NCDXF Board of Directors Sub-Committee
Sent: Thursday, November 06, 2014 2:08 PM
To: ncdxf-bod-sub at kkn.net <mailto:ncdxf-bod-sub at kkn.net> ;
ncdxf-bod-sub at kkn.net <mailto:ncdxf-bod-sub at kkn.net> 
Subject: Re: [NCDXF-BoD-Sub] Conference Call Postponed

I guess we need legal advice.   The use of NCDXF as a vehicle to gain tax
deductibility for team members was based on a Mormon Church ruling that
members going on a "recruiting" trip to Africa can run their expenses
through the Church for deductions.

I don't know if what Bob suggests is stretching the boundary of the tax
ruling.  How do we approve funding with no dollar limit.  Do we want to vote
before all the facts are in?

Can one of the old timers here remember how the Board came up with the
extension of tax deductibility to members of dxpeditions?

I don't want to jeopardize our tax-exempt status.

Don

At 01:28 PM 11/6/2014, NCDXF Board of Directors Sub-Committee wrote:

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W6OTC asked that I circulate this:

Overnight developments between USFWS and K4UEE on the topic of helicopter
transport have created a major additional financial wrinkle in the Navassa
expense budget. See K4UEE e-mail below.  We will re-schedule this conference
call once things become clear enough to make it worth our time.

73, Glenn W6OTC

From: Bob Allphin [mailto:k4uee at comcast.net] 
Sent: Wednesday, November 05, 2014 6:25 PM
To: W6OTC
Cc: Bob Allphin
Subject: Re: Navassa Island grant request

Glenn,
     Here is an update for you and the NCDXF Board.  Today, we had a telcon
with USFWS and they dropped a bombshell on us.  We knew from the beginning
that we were responsible for all costs associated with them accompanying us
to the island and providing security. We also knew that they always must
travel on government approved transportation and that FWS owned a helicopter
for that purpose.  We learned today that their pilot has recently retired
and they have been forced  to get transportation quotes from outside
contractors to transport the five FWS personnel to and from the Island.
Included in that quote is a large amount to be on standby for any emergency
situation that may require evacuation.  Anyhow, the amount that we had
estimated for these costs has now quadrupled to well over $100,000.
    Tomorrow, Glenn Johnson and I will be meeting with our helicopter
company in the Dominican Republic.  We are hopeful that we can negotiate a
lower price and maybe a "on standby" arrangement that might reduce the FWS
expense.  Bottom line is that we are not giving up, but in fact more
determined than ever.
    So, I respectfully ask that the NCDXF Board delay any decision as to the
level of funding until after we complete our negotiations with both FWS and
our helo company.  That said, we have a dilemma.  Most of the team members
want to run their team member contributions through NCDXF as "directed
contributions" so as to get tax deductibility.  We understand that is only
possible after NCDXF has decided that they will fund our project.  So, is it
possible to get a commitment to fund Navassa 2015 and allow us to get the
cash flow from our team members that we need to make our first deposit on
the helicopter. A decision on the level of NCDXF funding can be determined
after we have a better handle on the costs.
   As always, thanks for your consideration,
Bob-K4UEE
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