Some nonprofit agencies knowingly take advantage of this and file 990s that are inaccurate, experts say.

As a result, nonprofit agencies in general have ``a serious accountability problem,'' said Daniel Borochoff, president of the American Institute of Philanthropy in Chicago, a watchdog organization that monitors charities.

``Too many organizations are not taking these forms seriously in their responsibility to be accountable to the public,'' Borochoff said.

The IRS, he said, can only do so much.

``There's about 500 people in the IRS that ... audit the nonprofits,'' Borochoff said, and they oversee more than 1 million nonprofit agencies. ``It's limited what they can really do.''

Borochoff is one of three outside experts retained by The Tampa Tribune to review the public records of the Make-A-Wish Foundation of Sarasota/Tampa Bay.

Another of the three, David Burris, said that with manpower stretched so thin, IRS agents generally take up a case only when they find something suspicious in a random audit or are alerted to possible wrongdoing by another agency.

Even when fraud is suspected, cases are usually pursued as civil rather than criminal matters.

``The difference between having a dispute with the IRS and a criminal matter, or fraud, is intent,'' said Burris, a retired IRS special agent who spent 25 years with the agency.

``It's easy to prove intent in a bank robbery,'' Burris continued, but ``in a complex, complicated financial matter, it's ... harder.''

John W. Allman and Michael Fechter