Bulletin #50     HONDA   Re-Introduced - Section 6                              05/28/2006

 

This is the fifth of a series of bulletins NHELD is preparing detailing, section by section, the exact language of HR3753/S1691, the “Home School Non-Discrimination Act of 2005”, or “HoNDA”, as proposed in the House and Senate.  The bulletins will provide the exact language from the bill, along with the exact text of the existing federal law that the bill proposes to amend.  The bulletins will also include NHELD’s comments on those provisions.  The first bulletin was Bulletin #44 - HONDA  Re-Introduced Examining Sections 1, 2 and 3 issued 10/17/2005, and the second bulletin #47 was HONDA  Re-Introduced examining Section 4(a)  issued 01/23/06 and the third bulletin #48 was Section 4(b) issued 1/24/2005, and the fourth bulletin #49 was about section 5.

 

NHELD believes this entire bill should be killed and all previous federal laws already adopted having anything to do with the rights of parents to instruct their children at home should be repealed.

 

NHELD believes that there can be no compromises on any federal legislation regarding the rights of parents to instruct their children at home. 

 

NHELD believes all federal legislation regarding the rights of parents to instruct their children at home, no matter how beneficial the legislation appears, is wholly unconstitutional, in violation of the Tenth Amendment to the United States Constitution and must be defeated and/or repealed immediately.

 

As always, we strive to provide our readers with all of the facts so that they can reach their own conclusions. Please bear with us as we reprint the relevant and exact statute excerpts, which are both important and tedious at times to read.  Following the specifics of the legislation, we will provide you with a more reader-friendly analysis. 

 

Do you know what Section 6 of the HONDA bill does?  Section 6 of the proposed HoNDA bill purports to add certain language to an existing portion of the IRS Code. The portion of the IRS Code that would be amended is Section 530.  It can be found, in its entirety at:

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=browse_usc&docid=Cite:+26USC530

 

The Senate version of Section 6 of the Home School Non Discrimination Act, or HoNDA, S1691, is identical to the House version of Section 6 of HoNDA, HR3753. 

The Senate version of HoNDA, in its entirety, can be found at: http://thomas.loc.gov by searching for s1691.  The bill is currently before the Senate’s Committee on Finance.  In March and April of this year, four more Senators signed on to support its passage.

The House version of HoNDA, in its entirety, can be found at: http://thomas.loc.gov by searching for HR3753.  The bill is currently before the House Subcommittee on Education Reform.

 

 

Section 530 establishes provisions for Coverdell Education Savings Accounts.  Those are trust accounts set up for families to use tax exempt money to pay for certain educational expenses for children in elementary, secondary, and higher education.

 

Section 6 of the HoNDA bill would add a paragraph to that particular portion of the IRS Code, ostensibly, to allow home school families to benefit.

 

Section 6 of HoNDA, as proposed, reads as follows:

“SEC. 6. CLARIFICATION OF THE COVERDELL EDUCATION SAVINGS ACCOUNT AS TO ITS APPLICABILITY FOR EXPENSES ASSOCIATED WITH STUDENTS PRIVATELY EDUCATED AT HOME UNDER STATE LAW.

(a) In General- Paragraph (4) of section 530(b) of the Internal Revenue Code of 1986 (relating to qualified elementary and secondary education expenses) is amended by adding at the end the following new subparagraph:

 

`(C) SPECIAL RULE FOR HOME SCHOOLS- For purposes of clauses (i) and (iii) of subparagraph (A), the terms `public, private, or religious school’ and school’ shall include any home  school which provides elementary or secondary education if such school is treated as a home school or private school under State law.'.

 

(b) Effective Date- The amendment made by subsection (a) shall apply to taxable years beginning after the date of the enactment of this Act.”

 

The subparagraph proposed as the addition to the IRS Code, as underlined above, would be inserted into Section 530 so that the relevant portion of the IRS Code would read as follows:

 

 Sec. 530. Coverdell education savings accounts
 
(a) General rule
 
    A Coverdell education savings account shall be exempt from taxation 
under this subtitle. Notwithstanding the preceding sentence, the 
Coverdell education savings account shall be subject to the taxes 
imposed by section 511 (relating to imposition of tax on unrelated 
business income of charitable organizations).
 
(b) Definitions and special rules
 
    For purposes of this section--
 
               (1) Coverdell education savings account
 
        The term ``Coverdell education savings account'' means a trust 
    created or organized in the United States exclusively for the 
    purpose of paying the qualified education expenses of an individual 
    who is the designated beneficiary of the trust (and designated as a 
    Coverdell education savings account at the time created or 
    organized), but only if the written governing instrument creating 
    the trust meets the following requirements:
            (A) No contribution will be accepted--
                (i) unless it is in cash,
                (ii) after the date on which such beneficiary attains 
            age 18, or
                (iii) except in the case of rollover contributions, if 
            such contribution would result in aggregate contributions 
            for the taxable year exceeding $2,000.
 
            (B) The trustee is a bank (as defined in section 408(n)) or 
        another person who demonstrates to the satisfaction of the 
        Secretary that the manner in which that person will administer 
        the trust will be consistent with the requirements of this 
        section or who has so demonstrated with respect to any 
        individual retirement plan.
            (C) No part of the trust assets will be invested in life 
        insurance contracts.
            (D) The assets of the trust shall not be commingled with 
        other property except in a common trust fund or common 
        investment fund.
            (E) Except as provided in subsection (d)(7), any balance to 
        the credit of the designated beneficiary on the date on which 
        the beneficiary attains age 30 shall be distributed within 30 
        days after such date to the beneficiary or, if the beneficiary 
        dies before attaining age 30, shall be distributed within 30 
        days after the date of death of such beneficiary.
 
    The age limitations in subparagraphs (A)(ii) and (E), and paragraphs 
    (5) and (6) of subsection (d), shall not apply to any designated 
    beneficiary with special needs (as determined under regulations 
    prescribed by the Secretary).
 
                  (2) Qualified education expenses
 
        (A) In general
 
            The term ``qualified education expenses'' means--
                (i) qualified higher education expenses (as defined in 
            section 529(e)(3)), and
                (ii) qualified elementary and secondary education 
            expenses (as defined in paragraph (4)).
 
        (B) Qualified tuition programs
 
            Such term shall include any contribution to a qualified 
        tuition program (as defined in section 529(b)) on behalf of the 
        designated beneficiary (as defined in section 529(e)(1)); but 
        there shall be no increase in the investment in the contract for 
        purposes of applying section 72 by reason of any portion of such 
        contribution which is not includible in gross income by reason 
        of subsection (d)(2).
 
                (3) Eligible educational institution
 
        The term ``eligible educational institution'' has the meaning 
    given such term by section 529(e)(5).
 
(4) Qualified elementary and secondary education expenses
 
        (A) In general
 
            The term ``qualified elementary and secondary education 
        expenses'' means--
                (i) expenses for tuition, fees, academic tutoring, 
            special needs services in the case of a special needs 
            beneficiary, books, supplies, and other equipment which are 
            incurred in connection with the enrollment or attendance of 
            the designated beneficiary of the trust as an elementary or 
            secondary school student at a public, private, or religious 
            school,
                (ii) expenses for room and board, uniforms, 
            transportation, and supplementary items and services 
            (including extended day programs) which are required or 
            provided by a public, private, or religious school in 
            connection with such enrollment or attendance, and
                (iii) expenses for the purchase of any computer 
            technology or equipment (as defined in section 
            170(e)(6)(F)(i)) or Internet access and related services, if 
            such technology, equipment, or services are to be used by 
            the beneficiary and the beneficiary's family during any of 
            the years the beneficiary is in school.
 
      Clause (iii) shall not include expenses for computer software 
           designed for sports, games, or hobbies unless the software is 
           predominantly educational in nature.
 
        (B) School
 
            The term ``school'' means any school which provides 
        elementary education or secondary education (kindergarten 
        through grade 12), as determined under State law.
 

(C) SPECIAL RULE FOR HOME SCHOOLS- For purposes of clauses (i) and (iii) of subparagraph (A), the terms `public, private, or religious school’ and school’ shall include any home school which provides elementary or secondary education if such school is treated as a home school or private school under State law.”

 

 

Under Section 530 as it currently exists, a Coverdell Education Savings Account is a trust created exclusively for paying the “qualified education expenses” of the beneficiary of the trust. 

Of course, the law imposes certain conditions in order to benefit from such an account, as well as technicalities involving how the money can be distribute and under what circumstances. There is even a provision in Section 530 advising readers that other federal laws also apply to these accounts. In fact, references to other federal laws are sprinkled throughout Section 530, making it more time consuming to piece together the meaning of the law.  For example, as you can see from the text above, the existing law allows for a tax exemption for “qualified higher education expenses” and “qualified elementary and secondary education expenses”. As you also can see, Section 530 defines “qualified higher education expenses” by reference to a definition in section 529(e)(3).

 
http://66.161.141.176/cgi-bin/texis/web/usstat/+9wwBmeCFugen6pxwwxFqH6sm6+8hmhwmwmKhqq9_6XxmnvqmxwqhX/bvindex.html
 
Section 529(e)(3) defines “qualified higher education expenses” as:

     “(A) In general

      The term "qualified higher education expenses" means -

      (i) tuition, fees, books, supplies, and equipment required for the enrollment or attendance of a designated beneficiary at an eligible educational institution; and

      (ii) expenses for special needs services in the case of a special needs beneficiary which are incurred in connection with such enrollment or attendance.

      (B) Room and board included for students who are at least half-time

      (i) In general

      In the case of an individual who is an eligible student (as defined in section 25A(b)(3)) for any academic period, such term shall also include reasonable costs for such period (as determined under the qualified tuition program) incurred by the designated beneficiary for room and board while attending such institution. For purposes of subsection (b)(7), a designated beneficiary shall be treated as meeting the requirements of this clause.

      (ii) Limitation

      The amount treated as qualified higher education expenses by reason of clause (i) shall not exceed -

      (I) the allowance (applicable to the student) for room and board included in the cost of attendance (as defined in section 472 of the Higher Education Act of 1965 (20 U.S.C. 1087ll), as in effect on the date of the enactment of the Economic Growth and Tax Relief Reconciliation Act of 2001) as determined by the eligible educational institution for such period, or

      (II) if greater, the actual invoice amount the student residing in housing owned or operated by the eligible educational institution is charged by such institution for room and board costs for such period.”

In other words, “qualified higher education expenses” includes items like tuition, books, supplies and equipment “required for the enrollment or attendance” of a child “at an eligible educational institution”.  It also includes room and board for an “eligible student”, as defined in yet another section of the IRS Code, except for certain limitations on those allowable expenses.

Another portion of Section 529 provides further relevant and explanatory information. Section 529(e)(5), defines an “eligible educational institution”  as

 an institution -

      (A) which is described in section 481 of the Higher Education Act of 1965 (20 U.S.C. 1088), as in effect on the date of the enactment of this paragraph, and

      (B) which is eligible to participate in a program under title IV of such Act.”

In order to more fully appreciate that definition, one needs to read Section 481 of the Higher Education Act of 1965, 20 U.S.C. 1088.   http://66.161.141.176/cgi-bin/texis/web/usstat/+QwwBmeZFugenVVxwwxFqH6sm6+8hmhwmwmKhqq9_6XxmnvqmxwqhX/bvindex.html

Section 481 specifies:
 

“20 USC § 1088 Definitions

      SUBCHAPTER IV - STUDENT ASSISTANCE

      Part F - General Provisions Relating to Student Assistance Programs

      (a) Academic and award year

      (1) For the purpose of any program under this subchapter and part C of subchapter I of chapter 34 of title 42, the term "award year" shall be defined as the period beginning July 1 and ending June 30 of the following year.

      (2) For the purpose of any program under this subchapter and part C of subchapter I of chapter 34 of title 42, the term "academic year" shall require a minimum of 30 weeks of instructional time, and, with respect to an undergraduate course of study, shall require that during such minimum period of instructional time a full-time student is expected to complete at least 24 semester or trimester hours or 36 quarter hours at an institution that measures program length in credit hours, or at least 900 clock hours at an institution that measures program length in clock hours. The Secretary may reduce such minimum of 30 weeks to not less than 26 weeks for good cause, as determined by the Secretary on a case-by-case basis, in the case of an institution of higher education that provides a 2-year or 4-year program of instruction for which the institution awards an associate or baccalaureate degree.

      (b) Eligible program

      (1) For purposes of this subchapter and part C of subchapter I of chapter 34 of title 42, the term "eligible program" means a program of at least -

      (A) 600 clock hours of instruction, 16 semester hours, or 24 quarter hours, offered during a minimum of 15 weeks, in the case of a program that -

      (i) provides a program of training to prepare students for gainful employment in a recognized profession; and

      (ii) admits students who have not completed the equivalent of an associate degree; or

      (B) 300 clock hours of instruction, 8 semester hours, or 12 hours, offered during a minimum of 10 weeks, in the case of -

      (i) an undergraduate program that requires the equivalent of an associate degree for admissions; or

      (ii) a graduate or professional program.

      (2)(A) A program is an eligible program for purposes of part B of this subchapter if it is a program of at least 300 clock hours of instruction, but less than 600 clock hours of instruction, offered during a minimum of 10 weeks, that -

      (i) has a verified completion rate of at least 70 percent, as determined in accordance with the regulations of the Secretary;

      (ii) has a verified placement rate of at least 70 percent, as determined in accordance with the regulations of the Secretary; and

      (iii) satisfies such further criteria as the Secretary may prescribe by regulation.

      (B) In the case of a program being determined eligible for the first time under this paragraph, such determination shall be made by the Secretary before such program is considered to have satisfied the requirements of this paragraph.

      (c) Third party servicer For purposes of this subchapter and part C of subchapter I of chapter 34 of title 42, the term "third party servicer" means any individual, or any State, or private, profit or nonprofit organization which enters into a contract with -

      (1) any eligible institution of higher education to administer, through either manual or automated processing, any aspect of such institution's student assistance programs under this subchapter and part C of subchapter I of chapter 34 of title 42; or

      (2) any guaranty agency, or any eligible lender, to administer, through either manual or automated processing, any aspect of such guaranty agency's or lender's student loan programs under part B of this subchapter, including originating, guaranteeing, monitoring, processing, servicing, or collecting loans.”

Quite often the language of a statute is not as clear as it could be, leaving room for multiple interpretations.   One would assume that in order to obtain the tax break, the “eligible educational institution” would need to comply with the provisions in 20 USC § 1088 for an “eligible program.”  Looking at yet another provision of Section 529, Section 529(b)(1), the term "qualified tuition program" is defined as:

 a program established and maintained by a State or agency or instrumentality thereof or by 1 or more eligible educational institutions…” and which meets certain other requirements. That section also specifies that a program is not “qualified” unless it “received a ruling or determination that such program meets the applicable requirements for a qualified tuition program.”

In still another section, Section 529(d), it is explained that the officer or employee in control of the “qualified tuition program” is required to

 make such reports regarding such program to the Secretary and to designated beneficiaries with respect to contributions, distributions, and such other matters as the Secretary may require. The reports required by this subsection shall be filed at such time and in such manner and furnished to such individuals at such time and in such manner as may be required by the Secretary.” 

The reports are to be sent, presumably, to the Secretary of the Treasury, in charge of the IRS.

In order to participate in the Coverdell Education Savings Accounts regarding expenses for higher education, one can see that there are many provisions that the parents must abide by and there are still other provisions that a “qualified” educational institution or program must abide by to avoid penalties.

Regarding expenses for elementary and secondary education expenses, Section 530 of the IRS Code, as it exists today, specifies still other provisions. http://66.161.141.176/cgi-bin/texis/web/usstat/+FwwBmeCFugenG3xwwxFqHsmvs_xX8q8xs_KswxWX_m8q+ns+W6w9v/bvindex.html

     Section 530(b)(4) defines “Qualified elementary and secondary expenses” as:

        “(A) In general
 
            The term ``qualified elementary and secondary education 
        expenses'' means--
                (i) expenses for tuition, fees, academic tutoring, 
            special needs services in the case of a special needs 
            beneficiary, books, supplies, and other equipment which are 
            incurred in connection with the enrollment or attendance of 
            the designated beneficiary of the trust as an elementary or 
            secondary school student at a public, private, or religious 
            school,
                (ii) expenses for room and board, uniforms, 
            transportation, and supplementary items and services 
            (including extended day programs) which are required or 
            provided by a public, private, or religious school in 
            connection with such enrollment or attendance, and
                (iii) expenses for the purchase of any computer 
            technology or equipment (as defined in section 
            170(e)(6)(F)(i)) or Internet access and related services, if 
            such technology, equipment, or services are to be used by 
            the beneficiary and the beneficiary's family during any of 
            the years the beneficiary is in school.
 
        Clause (iii) shall not include expenses for computer software 
        designed for sports, games, or hobbies unless the software is 
        predominantly educational in nature.
 
        (B) School
 
            The term ``school'' means any school which provides 
        elementary education or secondary education (kindergarten 
        through grade 12), as determined under State law.”
 

In other words, under existing law, parents could get a tax exemption for tuition, fees, tutoring, special needs, expenses for room and board, and computer technology if those expenses are “incurred in connection with the enrollment or attendance of” the child as an “elementary or secondary school student at a public, private, or religious school”.   The term, “school” is defines as a “school which provides elementary education or secondary education…as determined under State law.” 

As stated above, the HoNDA bill, Section 6, would add to Section 530(b) the following paragraph to that section of the existing law:

“(C) SPECIAL RULE FOR HOME SCHOOLS- For purposes of clauses (i) and (iii) of subparagraph (A), the terms `public, private, or religious school’ and school’ shall include any home  school which provides elementary or secondary education if such school is treated as a home school or private school under State law.”

 

If this section of HoNDA is adopted, this new paragraph purportedly would entitle parents of homeschooled children to set up a Coverdell education savings account and use the tax exempt money in the trust to pay for:

 

       “(i) expenses for tuition, fees, academic tutoring, 
            special needs services in the case of a special needs 
            beneficiary, books, supplies, and other equipment which are 
            incurred in connection with the enrollment or attendance of 
            the designated beneficiary of the trust as an elementary or 
            secondary school student at a public, private, or religious          
            school”; and
 
     “(iii) expenses for the purchase of any computer 
            technology or equipment (as defined in section 
            170(e)(6)(F)(i)) or Internet access and related services, if 
            such technology, equipment, or services are to be used by 
            the beneficiary and the beneficiary's family during any of 
            the years the beneficiary is in school.”

So what’s wrong with that?  Wouldn’t it be beneficial for parents to be able to receive a tax exemption for money spent educating their child?  While it sounds like a good thing on the surface, in reality, it could prove to be a nightmare.

For one thing, parents could use the Coverdell Savings Account tax exempt money to pay for those expenses, but only if those expenses “are incurred in connection with the enrollment or attendance” of the child “as an elementary or secondary school student…”  Home schooled students in many states are not considered to be “enrolled in” or “in attendance in” any “school”.  In many states, the terms “enrolled” and “attendance” legally relate only to brick and mortar public and private schools, and not to children being instructed at home by their parents.  In such a case, either the parents would not be able to “benefit” from the tax exemption, or, the law would need to be changed such that homeschooled students would be considered “enrolled” and “in attendance.”  Once that law is changed, other laws may newly apply to homeschooled students.  One such law would be the “truancy” law.  In some states, “truancy” only applies to children who are “enrolled” or who “attend” a school and who have a certain number of “unexcused” absences.  Truancy might apply in those states where it never before applied.

For another thing, the bill provides for a new definition of the terms “public, private, or religious school” to include a “home school” “which provides elementary or secondary education” “if such school is treated as a home school or private school under State law.”  Let’s just examine that definition one step at a time.

Without having it spelled out anywhere in the new law, “public, private, or religious school” would also automatically mean a “home school”. What if during the debate on this bill on the floor of the House or the Senate, or in a conference committee meeting between the two houses, the bill is amended to include a provision regulating a public, private, or religious school” in some manner.  That regulation, whatever it is, necessarily, also would apply to a home school. What if that doesn’t happen during the debate on its passage, but next year, the year after that, or the year after that, the law is amended to include still more regulations.  Guess what?  The regulations, whatever they are, necessarily, also would apply to a home school.  Do we really want to leave the door open to this kind of interpretation and unintended consequence?

The bill also says that the terms “public, private, or religious school” will include a “home school” “which provides elementary or secondary education”.  That phrase also is open to interpretation.  Does it mean that the home school “provides elementary or secondary education” as defined by the federal government, by the state government, or by the parents? If it means that the home school “provides elementary or secondary education” as defined by any governmental entity, what exactly is the “education” that is supposed to be provided?  Is it the education provided in the richest public school in the state, the poorest school in the state, or the education that is “supposed” to be provided in accordance with some statute?  The bill certainly doesn’t make clear what elementary or secondary education is to be provided.  Do we really want to leave the door open to any kind of interpretation of this phrase by any governmental entity?  What kind of unintended consequence will that have?  What kind of governmental abuses will result when parents disagree with the government over the meaning of that phrase?

The bill also says the terms “public, private, or religious school” will include a “home school” “if such school is treated as a home school or private school under State law”.  In some states currently, a “home school” is treated as just that, a “home school”.  In other states, a “home school” is treated as a “private school”.  In still other states, what we think of as a “home school” is not defined in any way in state law as a “home school”.  It may be defined as “instruction by parents”, or it may not be defined at all but is assumed to be the mandatory duty of parents to instruct their children.  Under this proposed bill, only those parents whose children are educated in “home schools” that are “treated as a home school or private school under State law” would be eligible for the tax exemption.  What happens if the parents in one state disagree with the government in that state concerning the meaning of that state’s statutes regarding how a “home school” is “treated under State law”?  What if one group of homeschoolers wants to have “home school” “treated” as qualifying for the tax exemption, and another group of homeschoolers does not want to have “home school” “treated” as qualifying for it?  Do we really want to see those battles looming in our future?  What if, as a result of those battles, the “home school” law in that state changes completely?  What if the legislature in that state decides that more regulation is necessary, particularly if parents are going to receive a tax exemption?  What other unintended consequences will we face?

More importantly, consider this.  If the bill is adopted, and homeschoolers are able to receive a tax exemption for their expenditures, those expenditures will be subject to auditing by the Internal Revenue Service.  The IRS, with all of its awesome powers, will be authorized to scrutinize every book, every material, every supply you purchased to determine whether it qualifies for a tax exemption.  More than that, the IRS will have the authority to determine whether your “home school” qualifies as a “home school” under State law for purposes of obtaining the exemption.

Should the IRS deem your “home school” not to qualify as a “home school” under State law such that you improperly reported the expenditures as a tax exemption, you would be subject to all applicable fines and penalties, including, but not limited to imprisonment. Also, since the IRS is a governmental entity, and since there seems to be an increasing number of laws and exceptions to laws that promote the sharing of personal information from one governmental entity to another, there is little doubt that an agency such as the Department of Education or the Department of Children and Families could receive information that your “home school” does not “qualify” as a “home school under State law.”  In such a case, those Departments also are authorized to take steps to rectify the situation, including, but not limited to, fines, penalties, imprisonment, and taking the care and custody of the children away from the parents. 

After all, there already is a provision in Section 530 of the IRS Code that requires people participating in Coverdell Education Savings Accounts to “report” to the “Secretary”.  Section 530(h) specifies:

“(h) Reports
 
    The trustee of a Coverdell education savings account shall make such 
reports regarding such account to the Secretary and to the beneficiary 
of the account with respect to contributions, distributions, and such 
other matters as the Secretary may require. The reports required by this 
subsection shall be filed at such time and in such manner and furnished 
to such individuals at such time and in such manner as may be required.”

Take a look at that again.  The trustees, the banks holding the funds, are to make “reports” to the “Secretary”, that is, to the IRS, regarding the accounts “and such other matters as the Secretary may require.”   The Secretary could “require” almost anything to be “reported.” 

In addition, even though HoNDA section 6 purports only to add one paragraph to a section of the IRS Code, the IRS also can adopt regulations to “implement” the Code.  Generally speaking, Codes, or statutes, are adopted in fairly broad language.  Regulations are adopted by various governmental agencies in order to implement the statutes.  The regulations, therefore, are more specific and particularized in detail.  Also generally speaking, it can be more difficult to find out about proposed regulations and to affect their change should it become necessary.

The questions to ask regarding this section of HoNDA are these: Do we really want to open up another area in which the federal government can adopt regulations specifically having to do with whether our curricular books, materials, and supplies “qualify” as a home school tax exempt expense?  Do we really want to give that much authority to the Secretary of the Treasury for the IRS?  Do we really want to give such authority to individual IRS agents?  Do we really want to open our home school curriculum to anyone from the IRS for inspection and authorization?  Do we really want to suffer those kinds of consequences?  Is a tax exemption worth that kind of risk to a homeschooling family? NHELD thinks not.

 

 

 

Attorney Deborah Stevenson - Executive Director of National Home Education Legal Defense.www.nheld.com or email : info@nheld.com

Judy Aron - Director of Research, NHELD – imjfaron@sbcglobal.net