My comment pertains to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. So much good can come from giving to charities, for instance, research into developing a cure for a specific disease process which would be a shame.  A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker.