The Common Cause organization filed a complaint with the IRS under 26 USC 7623, the tax whistleblower act, alleging that the American Legislative Exchange Council violated the lobbying restrictions applicable to tax exempt organizations through underreporting and operating in furtherance of private corporate interests. The complaint argues that "ALEC's primary purpose is to provide a vehicle for its corporate members to lobby state legislators and to deduct the costs of such efforts as charitable contributions. ALEC drafts “model” legislation provided by its corporate and legislative members, and lobbies for the adoption of that legislation. These goals are fundamentally inconsistent with ALEC's claimed tax-exempt status as a charitable organization."
The following paragraphs are from the introduction to the complaint.
The complaint goes on to specify how ALEC develops legislation and works to get that model language enacted. The following is an excerpt from this portion.