Published September 26, 2026 · Evidence cutoff September 25, 2026
Seven Rivers RC&D — IRS filing review
Formatted C.L.O.C.K. research notes, not an official source. Underlying records and limitations are identified below. Personal contact details are withheld in this reading copy.
Seven Rivers RC&D — IRS filing review
Research working paper, September 25, 2026 (Eastern). Seven Rivers Resource Conservation & Development Area Inc, EIN 58-2001578. These are statements in filed returns, not independent verification of transactions. No finding of improper payments or taxpayer loss is established here.
Returns examined and source limits
- 2024 Form 990 and schedules, filed September 10, 2025.
- 2023 Form 990 and schedules, filed August 27, 2024.
- 2022 Form 990 and schedules, filed November 15, 2023.
Reviewed IRS-XML-derived visual returns in ProPublica's viewer: 2024 main return and Schedules D/O; 2023 main return and Schedule O; 2022 financial sections, employee count, and Schedule O. This is a source-linked extraction and analysis, not a saved native IRS return or a complete audit of every schedule. Native filing downloads were not successfully preserved in this review. Calendar years must not be directly equated to Appling's October–September fiscal years.
Three-year comparison
Amounts below are reported on the linked annual return, Parts VIII–XI. Blank expense fields are explicitly identified rather than silently treated as reported zeros.
| Item | 2022 | 2023 | 2024 |
|---|---|---|---|
| Total revenue | $729,110 | $611,777 | $495,946 |
| Government grants, VIII.1e | $541,803 | $461,707 | $377,760 |
| Membership dues, VIII.1b | $12,545 | $13,500 | $14,250 |
| Other contributions, VIII.1f | $56,002 | $33,810 | $28,063 |
| Program service revenue, VIII.2g | $115,273 | $98,440 | $50,331 |
| Investment income, VIII.3 | $3,487 | $4,320 | $25,542 |
| Total expenses, IX.25 | $778,856 | $328,194 | $302,902 |
| Revenue minus expenses | -$49,746 | $283,583 | $193,044 |
| Salaries/wages, IX.7 | $85,303 | Blank | $66,114 |
| Other employee benefits, IX.9 | $1,000 | Blank | Blank |
| Nonemployee management fees, IX.11a | Blank | $58,606 | Blank |
| Employees reported on W-3, V.2a | 0 | 0 | 0 |
| Ending net assets, X.32 | $991,126 | $1,273,611 | $1,466,655 |
| Net assets without donor restrictions, X.27 | $369,813 | $614,411 | $776,619 |
| Net assets with donor restrictions, X.28 | $621,313 | $659,200 | $690,036 |
2024 government grants as a share of revenue: $377,760 ÷ $495,946 × 100 = 76.17%. The return does not itemize those government receipts by county or agency. Neither the grant total nor membership dues can be assigned to Appling without supporting records.
The $11,808 noncash contribution reported in VIII.1g in each year is already included in contributions, not extra revenue to add again.
Payroll classification: a reconciliation question
The 2023 return reports no salary expense in its Part I summary and $58,606 in nonemployee management fees in IX.11a. The 2024 return reports $66,114 in salaries and wages in IX.7. Both report zero W-3 employees, as does 2022 despite that year's $85,303 salary entry. The reviewed Schedules O do not explain the classification changes or name Appling as the payee.
Inference to test: the County payroll arrangement may explain the employee count and expense classification. I cannot confirm this from these returns. Zero employees does not establish unpaid staff, missing payroll, or misconduct. The forms do not provide a transaction-level bridge to County receipts.
Ask for the payroll/service agreement, calendar-year reimbursements, invoice calculations, benefit and tax allocation, and general-ledger accounts mapped to Form 990. Establish who is employer of record and who bears health insurance, retirement, workers' compensation, administration, and any unreimbursed liability.
The largest expense category is now partly explained
2024 Schedule O explains IX.24e as:
- Project expense: $176,960.
- Taxes and fees: $148.
- Gain/loss on disposal of assets: -$38,000.
- Calculation: $176,960 + $148 − $38,000 = $139,108.
The negative asset-disposal entry reduces reported expenses. Removing just that offset for illustration gives $302,902 + $38,000 = $340,902, and $495,946 − $340,902 = $155,044. These are analytical calculations, not corrected financial statements or an operating cash-flow result. Obtain the asset sale/disposal records and audit accounting before characterizing the transaction.
2023 Schedule O: $172,924 project expense + $1,666 taxes/fees + $1,742 disposal entry = $176,332.
2022 Schedule O: $415,526 project expense + $200 staff education + $1,655 taxes/fees + $2,473 telephone + $1,800 utilities + $165,906 disposal entry = $587,560.
The changing project and disposal entries make simple expense comparisons potentially misleading. Project expense is still a broad label; it does not identify projects, vendors, or counties benefiting.
Assets are not all spendable cash
2024 Part X reports:
| Asset or balance | Amount |
|---|---|
| Non-interest-bearing cash | $563,910 |
| Savings/temporary cash investments | $104,186 |
| Cash plus savings, calculated | $668,096 |
| Notes and loans receivable, net | $690,036 |
| Prepaid expenses/deferred charges | $51,036 |
| Equipment, net | $96,736 |
| Total assets | $1,505,904 |
| Total liabilities | $39,249 |
| Net assets: assets minus liabilities | $1,466,655 |
Restricted net assets and net loans receivable are each $690,036. Their equality is observable; the applicable restrictions and loan-program accounting still require the audit notes and grant agreements. Do not call the $1.47 million total spare cash or assume every cash dollar is unrestricted.
2024 Schedule D, Part VI, identifies the $96,736 net fixed-asset balance as equipment. Parts XI/XII report audited financial-statement revenue and expenses equal to the return totals. The audit itself has not been examined; this does not establish an unqualified audit opinion.
The prior-year net-asset changes reconcile with disclosed prior-period adjustments, rather than unexplained arithmetic gaps:
- 2022: $1,070,452 − $49,746 − $29,580 = $991,126.
- 2023: $991,126 + $283,583 − $1,098 = $1,273,611.
- 2024: $1,273,611 + $193,044 = $1,466,655.
The reason for the prior-period adjustments remains open.
Governance statements worth following up
The 2023 and 2024 returns, VI.11a, say the complete return was not provided to all governing-body members before filing. Each reviewed Schedule O (2022–2024) states, for VI.11b: “No review conducted.” This concerns review of Form 990; it does not mean no financial audit occurred.
The 2023 and 2024 returns say a written conflict policy and annual interest disclosures existed, but answer no to regularly and consistently monitoring/enforcing that policy (VI.12a–c). They report independent financial audits but no committee responsible for audit oversight/accountant selection (XII.2b–c). These filed answers support questions about oversight; they do not establish an actual undisclosed conflict or unlawful conduct. The form itself describes Section VI.B as requesting policies not required by the Internal Revenue Code.
Connect the IRS review to the County budget hearing
Appling's proposed FY2027 worksheet contains $90,000 salary plus $5,000 FICA/Medicare = $95,000 in named Seven Rivers expense lines. Its revenue worksheet separately projects $100,000 in salary reimbursement. County budget copy, PDF p. 7 expenses and p. 3 revenues.
$100,000 − $95,000 = $5,000. This limited comparison is not proof of a County profit, just as $95,000 alone is not proof of a net subsidy. Full benefits, costs, receipt timing, and agreement terms must be reconciled. FY2026 year-to-date receipts of $112,976.66 cannot be paired with blank year-to-date expense cells to calculate a reliable net result.
Other counties' support is documented separately in the regional support review. County dues and a reimbursed payroll arrangement are different transactions; compare net costs only after identifying both sides.
Priority hearing questions
- What agreement authorizes Appling to carry Seven Rivers payroll, and does reimbursement cover every associated cost?
- Can the County provide a fiscal-year reconciliation of actual payroll, benefits, administration, reimbursements billed, reimbursements received, and outstanding balances?
- Which Seven Rivers ledger accounts contain payments to Appling, and how do those amounts map into salaries versus management fees on the 990?
- Which governments supplied the reported grants and dues, under what restrictions, and what services or projects benefited Appling residents?
- Can the audited statements and notes explain the loan fund, restricted balances, asset disposals, and prior-period adjustments?
- What financial reporting does the Commission receive before renewing the arrangement, and what corrective steps address the oversight answers in the returns?
Evidence status
Confirmed document facts: amounts and answers appear in the identified rendered returns. Filed statements: underlying balances, expense classifications, audit existence, and governance answers are Seven Rivers' representations. Inference: County payroll could explain zero direct employees and the classification changes. Open: transaction matching, actual taxpayer net cost, donor restrictions, audit opinion, county-specific outcomes, and disposal details. No established contradiction: zero W-3 employees and salaries may have an explanation; do not label this fraud, double payment, or an erroneous return without it.
Update log
- September 25, 2026: Compared 2022–2024 IRS-derived returns; reviewed explanatory schedules; reconciled the net-asset movements and 2024 other-expense total; preserved source links and hearing questions. No external request or publication sent.