Texas Ethics Commission
The Texas Ethics Commission is authorized by Texas Civil Statutes, Article 6252-
9d.1, 1.29, to issue advisory opinions in regard to the following statutes: 
Texas Civil Statutes, Article 6252-9b; the Government Code, Chapter 302; the 
Government Code, Chapter 305; the Election Code, Title 15; the Penal Code, 
Chapter 36; and the Penal Code, Chapter 39.
Requests for copies of the full text of opinions or questions on particular 
submissions should be addressed to the Office of the Texas Ethics Commission, 
P.O. Box 12070, Austin, Texas 78711-2070, (512) 463-5800.

Opinions
AOR-117. The Ethics Commission has been asked to consider the following 
questions: whether a donor must report expenditures for food, transportation, 
lodging, or entertainment provided to a county official; and whether a county 
official is required to report food, lodging, transportation, or entertainment 
accepted as a "guest."

AOR-118. The Ethics Commission has been asked to consider whether a county 
official must register as a lobbyist if the county official communicates 
directly with members of the legislator in his capacity as a representative of a 
private association of county officials.

AOR-119. The Ethics Commission has been asked about the application of the 
provisions of Senate Bill 1 to a situation in which the LBJ School of Public 
Affairs co-sponsors a pre-session conference for legislators. The request letter 
states that the conference includes an orientation session for newly-elected 
legislators that provides "an opportunity for the new members to learn about 
state budgeting, fiscal management, health and human services and other state 
operations," The question raised is whether the Penal Code, Chapter 36 prohibits 
the use of non-appropriated university funds to pay travel, food, and lodging 
expenses for newly-elected members. The request letter also asks about the 
propriety of providing lunch for all legislators who attend.

AOR-120. The Ethics Commission has been asked to consider whether the following 
situation involves an illegal political contribution by a corporation: Smith 
Corporation is the managing agent for Jones Partnership. Jones Partnership is 
the owner of a piece of rental property managed by Smith Corporation. A general 
purpose PAC receives a contribution from "Smith Corp., managing agent for Jones 
Partnership." The account is operated by Smith Corporation for the sole purpose 
of handling Jones Partnership funds. The funds belong to Jones Partnership, even 
though they are distributed by Smith Corporation.

AOR-121. A former executive head of a state agency has asked the Ethics 
Commission about the imposition of a $100 for failure to timely file a financial 
disclosure statement under Texas Civil Statutes, Article 6252-9b. The former 
executive head left his position in early April, before the filing deadline on 
April 30.

Issued in Austin, Texas, on October 27, 1992.
TRD-9214547
Sarah Woelk
Director, Advisory Opinions
Texas Ethics Commission
Filed: October 28, 1992
For further information, please call: (512) 463-5800