The acting commissioner of the Internal Revenue Service, Steven Miller, has been forced to resign days after the IRS apologized to tea party and other right-wing groups for putting extra scrutiny on their bids to become tax-exempt organizations. While the IRS targeting of tea party groups has made headlines for days, far less attention has been paid to the roots of the crisis. After the 2010 landmark Supreme Court decision Citizens United, there was a spike in new political organizations seeking tax-exempt status under tax code Section 501(c)(4). The court ruled these groups could raise unlimited corporate money without disclosing donor information. Several groups have claimed to be social welfare organizations while spending tens of millions of dollars on political operations.