TEXAS ETHICS COMMISSION
The Texas Ethics Commission is authorized by Government Code, sec.571.091, to 
issue advisory opinions in regard to the following statutes: the Government 
Code, Chapter 302; the Government Code, Chapter 305; the Government Code, 
Chapter 572; 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.

Texas Ethics Commission
Opinion Requests
AOR-256. The Texas Ethics Commission has been asked to consider whether a 
limited liability company (L.L.C.) may make political contributions under Title 
15 of the Texas Election Code.
AOR-257. The Texas Ethics Commission has been asked to issue an advisory opinion 
in regard to a situation in which an officeholder placed $800 in political 
contributions into an account used for personal expenditures. The transfer 
created a balance of $821.20 in the "personal account." Over the next few days, 
the officeholder withdrew $195 in cash from the account and wrote checks on the 
account totalling $164.93. After those transactions occurred, the officeholder 
placed $800 in personal funds into the account used for political expenditures. 
The Ethics Commission has been asked to consider the following questions based 
on those facts.
1. Does the payment of $800 in personal funds into the account used for 
political expenditures "adequately resolve the potential of a conversion" of 
political contributions to personal use?
2. If the original $800.00 transfer is a reimbursement for political 
expenditures from personal funds, did a conversion of political contributions to 
personal use occur?
3. Is the "mere personal control" of cash a conversion of political 
contributions to personal use.
4. Should the officeholder tender payment to the state under Election Code, 
sec.253.035(f) and, if so, in what amount?
AOR-258. The Texas Ethics Commission has been asked whether, under the campaign 
finance law, pledges of money to be transferred in the future, are to be 
reported in the report covering the period when the pledge was made.
Questions on particular submissions should be addressed to the Texas Ethics 
Commission, P.O. Box 12070, Austin, Texas 78711-2070, (512) 463-5800.
Issued in Austin, Texas, on October 5, 1994.
TRD-9449125
Sarah Woelk
Director, Advisory Opinions
Texas Ethics Commission
Filed: October 6, 1994