Module 4: Citizen Action Card, How to Audit an Entity Stack in Five Minutes
How to Audit an Entity Stack — (c)(3), (c)(4), PAC, LLC — in Five Minutes
Shadow Patriots Action Library · Project Milk Carton
Pairs with Module 4: “The Russian Doll” — Entity Laddering
You now know what a stack is — a group of legally separate organizations run by the same operator, with money moving up the rungs and changing its legal identity at every transition. This card teaches you how to map a stack from public filings, how to spot the opacity signals, and what questions to ask when you find them.
What a Stack Looks Like on Paper
Every rung of the ladder leaves a paper trail in a different place. You cannot read the whole stack from any single filing. You have to read five filings and stitch them together. Here is the map.
The 5-Minute Stack Audit
Step 1 — Start with the (c)(3)
Go to projects.propublica.org/nonprofits/ and search for the organization you care about. Pull the most recent 990.
Open Schedule R (“Related Organizations and Unrelated Partnerships”). This is the rung map. Schedule R lists: - Related tax-exempt organizations (other (c)(3)s and (c)(4)s) - Related taxable corporations or partnerships - Related entities the organization has common control with
If Schedule R lists a (c)(4) by name — you have just found the next rung of the ladder.
Step 2 — Pull the (c)(4)’s 990
Search the (c)(4) on ProPublica. Pull its most recent 990.
Check three things: - Schedule I (Grants Paid): Does the (c)(4) make grants to other entities? Who? - Part VII (Compensation): Who are the officers? Cross-reference against the (c)(3)’s officer list. Shared officers are the strongest indicator of a coordinated stack. - Part IX (Statement of Functional Expenses): Are there large, unlabeled line items for “consulting,” “management fees,” or “professional services”? These are often where LLC insertions hide.
Step 3 — Trace the LLC
If the (c)(4) shows a large payment to a consultant or LLC on Part IX or Schedule O, note the LLC’s name. Then go to the Secretary of State website for Delaware, Nevada, or Wyoming (those are the three most common formation states) and search the LLC name.
Most LLCs in those states disclose only a registered agent — not the actual members or owners. But the registered agent address often matches the (c)(4)’s address, or the address of a D.C. law firm that also shows up on the officer list. That is the pattern that says “the LLC and the (c)(4) are the same operation.”
Step 4 — Check the FEC for the PAC
Go to fec.gov and search for a PAC whose name resembles any of the entities you have found. Pull the most recent Form 3X.
On the PAC’s donor disclosure, look at the top five donors. Are they: - Individual humans? (traceable) - Other PACs? (traceable upstream) - (c)(4)s? (the ladder is live — the money came from upstream and cannot be traced past the (c)(4))
If the (c)(4) from Step 2 appears as a top donor to a PAC on the FEC — that is the full ladder. (c)(3) → (c)(4) → PAC, with the donor identity erased in the transition between Rung 2 and Rung 3.
Step 5 — Calculate the Stack’s Opacity Score
Count these five signals. Each one is worth one point:
Related (c)(4) on Schedule R of the (c)(3)? (+1)
Shared officers between (c)(3) and (c)(4)? (+1)
Large unlabeled LLC consulting payment on the (c)(4)’s 990? (+1)
LLC registered in Delaware/Nevada/Wyoming with no disclosed owners? (+1)
(c)(4) appears as a donor to a Super PAC on the FEC? (+1)
0–1: Routine stack. Compliance structure with visible accountability. 2–3: Intentional stack. Worth understanding — not necessarily worth flagging. 4–5: Opaque stack. Every disclosure seam is being used to break the paper trail. This is the architecture the series is teaching you to see.
Quick Reference: Stack Red Flags (Not Proof — Just Questions Worth Asking)
Your Assignment
Pick ONE of these:
Option A — The Stack Walk: Take the (c)(3) you audited in Module 3. Pull its 990 and open Schedule R. If it lists a related (c)(4), run the full Stack Audit above. Calculate the Opacity Score. Report what you find.
Option B — The FEC Upstream: Go to FEC.gov and pick any current Super PAC whose name you recognize. Pull its Form 3X. Look at its top five donors. How many are (c)(4)s rather than humans? Every (c)(4) on that list is a dark-money rung — the original donor is invisible.
Option C — The Shared Address: Go to OpenCorporates.com or your state’s Secretary of State website. Search for a D.C. address you suspect houses multiple nonprofits (the article footnotes list a few common ones). How many legally separate entities share that address? How many share officers? You are looking at the shape of the stack from the outside in.
Report what you find. Post it in the comments. Tag us. Every citizen who maps a stack makes the architecture one step more visible.
Shadow Patriots Action Library · Module 4 · Project Milk Carton · 501(c)(3) · EIN 33-1323547