A Washington-based organization with strong Republican Party ties is spending tens of thousands of dollars to promote two incumbent GOP congressmen in Pennsylvania, taking advantage of election-law gaps to avoid disclosing where it gets its money.

The group, the American Action Network, was established in February by former U.S. Sen. Norm Coleman, a Minnesota Republican, to "create, encourage and promote center-right principles," according to its Web site. Its board includes other prominent Republicans from Congress, Wall Street and corporate America.

It began running Philadelphia television ads last week praising U.S. Rep. Jim Gerlach, whose district includes pieces of Berks, Chester, Lehigh and Montgomery counties, and U.S. Rep. Charlie Dent, who represents Allentown, Bethlehem and other parts of Lehigh, Northampton, Berks and Montgomery counties.

To avoid registration requirements set by the Federal Election Commission, the TV ads do not expressly urge viewers to vote for either congressman.

Instead, they feature a small-business owner who drives around in a pickup truck and praises both congressmen for understanding businesses and jobs.

"They keep a sharp eye on Washington spending . . . and keep my taxes down," the businessman says, finally urging viewers to call the congressmen and thank them. The telephone number provided is for the main switchboard at the U.S. Capitol.

Rob Collins, a former chief of staff to U.S. Rep. Eric Cantor, a House Republican leader, is identified on the Action Network's Web site as its president. He did not return calls from the Daily News asking where the organization gets its money or how much it intends to spend in Pennsylvania.

An article last month in the National Journal said the group was trying to raise more than $25 million for this year's elections. Coleman, the group's chief executive officer, said it wanted to be active in about 25 House contests and eight to 10 Senate races, and intends to take advantage of January's U.S. Supreme Court ruling permitting corporations to make political contributions.

"We'll use the tools available to us in the post-Citizens United [world]," Coleman told National Journal.

Before the Citizens United case, corporations were not allowed to contribute directly to federal candidates or make payments to independent organizations, like the American Action Network, which wanted to weigh into federal campaigns.

By advertising so far in advance of the November election, and avoiding express language that would urge people to vote for Gerlach or Dent, the Action Network also skates outside the jurisdiction of the Federal Election Commission, allowing the group to spend money on its ads without identifying the donors who provided the money.

Spokesmen for Dent and Gerlach said they knew nothing about the ads until they began appearing last week.

The political director for the Gerlach campaign, Mark Campbell, minimized the significance of the ads, suggesting they would not make up for six years of negative telephone robocalls spreading misinformation about Gerlach's record in Congress.

"The fact is, for every one penny a Republican group spends, the Democrat-, [George] Soros-, union-backed hate groups are spending 99 cents," Campbell claimed.

He said Gerlach supported disclosure of the source of any of the organizations' money.

"Openness and transparency in campaigns is a goal we should all be striving for," he said. But he added: "Democrats are in control of both houses of Congress. If they wanted this to stop they could stop it any day they choose."