still who wrote it and distributed it via email to the IRS low level people? there must be a digital path to ownership of the questionnaire. Perhaps a smart lawyer out there should have recognized it as an illegal form under the regulations and challenged the need to respond to that. I remember such cases when I was working in the Government. They held our feet to the fire on creating and send out unapproved forms.
Having done that I remember the way to deal with things outside the formal process was to just write a memo!
No form is needed ~ the bureaucrat sits down and writes the memo to the supplicant and asks for information ~ and might even specify the format, but probably not.
The only time you need a form is when you have a large number of supplicants with essentially the same 'prey thee lord take pity on my request' situation. Otherwise you just cite a rule in the regulations and away you go.
Asking for the names of donors is simply prohibited ~ asking for the names of OWNERS (of a periodical) OR the names of principal OFFICERS (for any sort of corporation) would always be acceptable.
That's not what was happening here ~ they asked for names of donors, or members.
No form would be provided ~ so I just did a search at >http://search.irs.gov/search?q=donors&output=xml_no_dtd&proxystylesheet=irs_portals_frontend&client=irs_portals_frontend&oe=UTF-8&ie=UTF-8&num=10&ud=1&exclude_apps=1&site=default_collection&numgm=5&requiredfields=-archive%3A1
Someone might have snatched up one of the various documents listed to use for this other prohibited practice of course ~ but that'd be one smart cookie ~ well versed in IRS Processes ~ likely not a terribly low level worker at all!
BTW, agency lawyer rarely know enough about the agency to challenge the subject matter specialists on anything!