The TONY AND ALICIA GWYNN FOUNDATION has kept "incomplete records and been accused of misusing the foundation's funds," according to Washburn & Hasemyer of the SAN DIEGO UNION-TRIBUNE, who noted that the foundation was started in '94. Washburn & Hasemyer wrote that the foundation "has failed" to register as a charity in CA and has "been accused of asking" an employee to solicit donations while it wasn't registered, a technical violation of the law. Also, money in the charity's account has been written off under circumstances the foundation "can't explain." In '98, the foundation turned in a blank tax form to the IRS that listed no revenues or expenses and net assets of "only" $856. Washburn & Hasemyer added that "of the funds accounted for" from '95 to '99, 38% went to charities and the other 62% went to expenses such as professional fundraisers, sales commissions, a golf course rental and entertainment. No one associated with the foundation, including the Gwynns, would answer reporters' questions about its giving ratio or record-keeping. MA- based Giving Back Fund President MARC POLLICK, on the foundation: "There is something wrong. That foundation is being managed badly" (S.D. UNION-TRIBUNE, 12/13).