Adam B over at dailyKos has an excellent breakdown of the lengths to which the Fred Thompson campaign is going to have its campaign finance cake and eat it too. You'll recall that in May, Thompson announced he was entering a "testing the waters" phase. What does this mean exactly?

According to the FEC:

Before deciding to run for federal office, an individual may first want to "test the waters" -- explore the feasibility of becoming a candidate. For example, the individual may want to travel around the state to see if there is sufficient support for a possible Senate candidacy.

An individual who spends money only to test the waters (but not to campaign for office) does not have to register as a candidate under the election law.

The FEC is also quite specific about just what constitutes passing from the "testing the waters" phase to "campaigning for office," and Adam B documents the myriad ways in which Thompson, by any objective measure, appears to be breaking these rules in order to extend the testing the waters phase so as to avoid having to declare his fundraising to the FEC (not to mention he wouldn't want to miss all those Law & Order royalty checks!)

   *  If you raise funds in excess of amounts reasonably required for exploratory activity or amass funds for use after candidacy is established; (check and check)
    * If you conduct activities over a protracted period of time (or shortly before an election); (check)
    * If you make or authorize statements that refer to yourself as a candidate. (check, check and check)

What makes this ploy particularly brazen is that Thompson had been a champion of campaign finance reform in the 90s:

Thompson sponsored and worked alongside Sen. John McCain as one of the few Republicans who pushed for passage of campaign finance reform in 2001. At the time the bill was passed, Thompson issued a press release declaring, "The McCain-Feingold bill will restore a campaign finance system that has become more loophole than law."

Not to mention who he has working with him now to do it up right:

With the help of a former FEC chairman on Thompson's payroll, the ex-Tennessee senator is evading, at least for now, the requirements of the campaign finance system that he helped reform. In the words of an attorney associated with another campaign, Thompson is "playing footsie" with the campaign rules.

But the Thompson campaign seems prepared for resistance. As one campaign official told The Politico:

one way the former senator may push back against calls for him to show his money is to file with the Internal Revenue Service as a section 527 political organization, a section that includes political parties.

[snip]

"If we file with the IRS, that'll take the wind out of the sails of their disclosure argument," the official said.

Touché, unnamed campaign official. Touché.

Update [2007-7-17 3:1:49 by Todd Beeton]: Looks like the heat was too much for the Thompson camp to take. Geez, if he caves this easy now, imagine if he wins the nomination. This could get fun.

...on July 31 the "Friends of Fred Thompson" committee will go public with that information when it files a report of contributions and expenditures through June 30 with the Internal Revenue Service, according to Burson Snyder, a Thompson spokesperson.