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In that example, the tone would be the problem. In other examples, the facts could be challenged. But the fact/tone problems are interrelated. For instance, let's take this example:

> As early as 1964, George H.W. Bush, running for the U.S. Senate from Texas, was labeled by incumbent Democrat Ralph Yarborough as a hireling of the sheik of Kuwait, for whom Bush's company drilled offshore oil wells.

Now the word "hireling" here both asserts a fact and conveys a certain tone, i.e., implying that the Sheikh of Kuwait dictated to "Bush's company" (as if no one else but Bush participated in the company) as a boss dictates to a "hireling". No mention is made of the fact that there were numerous investors in "Bush's company" (including associates of leading Democrats Joseph Kennedy and Katherine Graham), nor is there consideration of the role they played in managing the company or how Bush's participation functioned in that context. What was Bush's position and function within the company? Did he make managerial decisions by himself, or did others have input? Were company policies dictated solely by the Sheikh of Kuwait or were there other variables involved? Phillips considers none of these questions. The entire dynamic of the company is reduced to labelling Bush a "hireling". BTW, Phillips is getting his information for this statement--probably indirectly--from Chapters 8 and 9 of Webster Tarpley and Anton Chaitkin's (i.e., Lyndon LaRouche's) "George Bush: The Unauthorized Biography", which are largely rehashing dirt dug up against Bush by Ralph Yarborough during the 1964 campaign. Phillips is not breaking any news here, just repeating an old hit piece, here and elsewhere in the article.