Since at least April -- well before he announced his decision not to run for a third term -- Gov. Pawlenty has been laying the organizational and financial groundwork for a potential run for president.

Fund-raising is under way for an organization that would allow Pawlenty to travel around the country, showing his face, developing his message and forming alliances with like-minded Republicans. Professional political fund-raisers are working on this.

Pawlenty has directly addressed groups of potential donors, and checks have been written.

According to a donor who attended one of the meetings, at the Minneapolis Club downtown, Pawlenty did not say that he was running for president, nor even that he was exploring a bid. He told the group the same kinds of things he has said in recent interviews -- that the party needs new ideas and fresh faces, friendlier voices than Rush Limbaugh’s, fresher faces than Newt Gingrich’s.

The donors asked Pawlenty about his presidential plans, and he “completely ducked and was purposefully noncommittal,” the donor said.

Pawlenty has also held meet-and-greet events in Washington, including one with former staff of the McCain for President campaign.

None of this commits Pawlenty to run for president, and he is a long way from the formation of an exploratory committee. Up to now, he has been unwilling to acknowledge that he is even thinking about a presidential candidacy.

I have asked members of Pawlenty’s political inner circle explicitly about the plan, but so far they have been unwilling to divulge any details. At least one of them lied to me and said he knew of nothing that was in the works. I don’t really see why it is necessary to be this secretive, but that's their call.

The likeliest structure for the current phase would be the formation of a 501(c) (4) organization (named for the chapter of the tax code under which it operates). I have substantial reason to believe that this is what Team Pawlenty has created or is in the process of creating.

According to Minneapolis lawyer Sarah Duniway, who specializes in working with nonprofits and election law, a 501 (c) (4) is a nonprofit, tax-exempt organization that can engage in issue advocacy and public education. It can fund-raise to support itself, put on issue conferences around the country, hire people to conduct research, even pay for polling if the polling is arguably related to the issues on which it was advocating. (Fulll disclosure: Duniway is married to my MinnPost teammate David Brauer.)

The funds of such an entity could be used to pay Pawlenty’s expenses to travel around the country giving speeches, related to issue advocacy. The issue can be fairly vague and general -- like the need for new ideas. Over time, the issue ideas could become more specific.

The organization must be nonpartisan, but certainly can be ideological, meaning that “new ideas for the conservative movement” would be an acceptable framework. New ideas to help Republicans win elections would not.   

A  501 (c) (4) also provides plenty of protection from prying eyes. The first public disclosures do not have to be made until after the end of the organization’s first fiscal year. There is no limit to the amount an individual can give. The organization does not have to even report to the IRS the identities of donors who give less than $5,000. And the names of the biggest donors, while reported to the IRS, do not have to be publicly disclosed, ever.

Another advantage of a 501 (c) (4) is that it is relatively easy to form one and gain tax-exempt status, although the contributions to a 501 (c) (4) are not tax deductible.

None of the money raised by the 501 (c) (4) could ever be converted to the treasury of a Pawlenty for President campaign committee. And the 501 (c) (4) cannot contribute to other candidates.

Another step that many politicians who are thinking about future campaigns create is called a Leadership PAC, which can raise money and contribute up to $5,000 each to candidates for office. Exploratory candidates sometimes go this route in order to build up political IOUs by contributing to candidates for lesser offices. I have no information at this point that Pawlenty is creating a leadership PAC. There is nothing in the law to prevent him from doing so and traveling under the auspices of a 501 (c) (4) at the same time.