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The organization has between 2,500 and 3,000 members, according to Mr. Parsi, but had fewer than 500 responses to a membership survey conducted last summer, internal documents show. Yet NIAC asserts that it is the largest such group and represents the majority of the nearly 1 million Iranian Americans.

Mr. Parsi defended his decision to organize NIAC as a 501(c)(3) nonprofit organization and declare on tax forms that his group does not engage in lobbying - a status that enables donors to deduct contributions on their taxes.

“NIAC is a 501(c)(3) educational organization that engages in advocacy and also has a right to engage in lobbying,” he said. “But we are not a (c)(4), we are not a lobby. Is there anything wrong in being a lobby? Not in our view. But this is what we are, at this stage.”

However, in a July 2008 memo obtained by The Times, Mr. Disney quoted the Lobbying Disclosure Act - a law that says even the preparation of materials aimed at influencing legislation or policy must be disclosed to the public - and said he and a colleague should register as lobbyists.

“Under this expansive view of ‘lobbying,’ I find it hard to believe Emily, and I devote less than 20 percent of our time to lobbying activity. I believe we fall under this definition of ‘lobbyist,’ ” he wrote, referring to NIAC’s legislative director at the time, Emily Blout.

The tax code allows nonprofits to devote less than 20 percent of their activities to lobbying if they declare the activity in a special section on their taxes. NIAC’s latest tax form shows that the group has declared that it spends none of its time lobbying.

When asked about his policy director’s memo, Mr. Parsi said that Mr. Disney is not a lawyer and that when he wrote the memo, he was new to the organization.

When reached Thursday for the story, Mr. Disney said, “You are using an e-mail from very early in my time at NIAC to demonstrate that the organization is not following the rules. When I wrote the e-mail in question, I was a 22 year old with no legal education, but was asked to research and give an opinion about a complex legal matter.

“The opinion I expressed in the email was erroneous, and has since been clarified by legal professionals who have found NIAC is in full compliance with the law. The practice of using out of context and partial e-mails is poor journalism; and it is one of the reasons Americans are losing faith in the media.”

Repeated efforts to reach Ms. Blout were unsuccessful.

An Iranian AIPAC

The genesis of NIAC goes back more than a decade to when Mr. Parsi was a student in Sweden. In 1996, he met another Iranian expatriate, Siamak Namazi. Mr. Namazi had a degree in urban planning but had recently joined a firm in Iran that sought to bring Western business standards to the Islamic Republic.

Mr. Parsi launched his first organization, Iranians for International Cooperation, in 1997, the year Iran elected a reformist, Mohammad Khatami, as president.

The group, which remained active until NIAC was founded, was designed to “safeguard Iran’s and Iranian interests,” according to its former Web site, which listed as its top priority “the removal of U.S. economic and political sanctions against Iran, and the commencement of an Iran-U.S. dialogue.”

Mr. Namazi wrote in a Nov. 9, 1998, essay for, that the group could have an important role to play in Washington but “we have a long way to go on the road to having our weight felt in American politics.”

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