Spencer Springer is a dynamic motivational speaker who writes books and gives inspiring messages about how to reach your highest potential in your life. Spencer has written over 20 books on the topic, and continues to write a book once every three years. The content of the books overlaps considerably.

Spencer is the president of "Reach for the Summit," which provides educational programs that teach the public how to realize their full potential as human beings. Reach for the Summit has a great deal of data on how lives have been transformed through its programs. Reach for the Summit is a tax exempt educational charity. The board consists of five members of Spencer's family. The organization has a Chief Operating Officer, Janice Johnson, who generally runs the organization. Spencer spends all of his time as president in the writing of books and speaking a seminars.

Reach for the Summit holds weekend seminars 48 weekends each year. Spencer is the sole speaker, and there are on average 5000 people in attendance at each weekend event. The charge to attend is $50 and includes a box lunch on both Saturday and Sunday. Spencer is paid $25,000 per year in his full time role as President. Janice is paid $200,000 as COO. While Spencer has never discussed the ownership of his books with the rest of the board of directors of Reach for the Summit, they know that he has claimed a copyright interest in his books.

At each weekend conference, Spencer has set up a book table at the entrance to the conference room. It is staffed by employees of Reach for the Summit. Spencer has never discussed paying anything to Reach for the Summit for the right to use a book table, and in fact does not pay anything. He promotes the books heavily during his inspirational talks, and the conference attendees generally buy several books each during the conference. At the end of each conference, the Reach for the Summit employees turn over all the funds from book sales to Spencer.

In the last three years, Spencer has earned an average of $8 million per year in books sales

What are the issues that the IRS is likely to raise as a matter of concern in the conference operations of Reach for the Summit?

What steps could Reach for the Summit take that would tend to satisfy the IRS in addressing the concerns you identified in question 1?