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TO:    Eric. L. Burkland, Treasurer, Ohioans for Responsible Health Information.

You have requested an opinion on the following:

In anticipation of terminating its existence, may Ohioans for Responsible Health Information, a ballot issue PAC, distribute funds primarily derived from corporate donors to a 501 (c)(6) non-profit corporation?

SYLLABUS: Ohio law does not allow a ballot issue political action committee (PAC) to distribute funds in its possession to an IRC Sec. 501(c)(6) non-profit corporation because the distribution would not be an "expenditure" as that term is defined in R.C. 3517.01(B)(6) and would, therefore, be an improper distribution of the PAC's funds.