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.

Ethics Adivsory Opinions
EAO-336. Whether a corporation may make candidates' campaign material available 
to corporate employees. (AOR-366). 
Summary. A corporation that provides all candidates the same opportunity to make 
campaign materials available to corporate employees would not be making a 
campaign contribution. In this context "the same opportunity" means not only 
that all candidates must be given the opportunity to provide information, but 
also that the corporate communications to each candidate regarding the 
opportunity to provide information must be essentially the same and that the 
corporation must handle each candidate's information in the same way.
EAO-337. Whether the "revolving door" law prohibits a former employee of the 
comptroller from acting as legal counsel for a taxpayer in a "redetermination 
proceeding" that disputes the results of a sales tax audit the lawyer provided 
advice on while an employee of the comptroller. (AOR-373). 
Summary. A sales tax audit and a redetermination proceeding in which the audit 
findings are disputed are part of the same "matter" for purposes of 
sec.572.054(b) of the Government Code.
EAO-338. Application of sec.305.026 of the Government Code and title 15 of the 
Election Code to a nonprofit corporation which includes various political 
subdivisions as dues-paying members. (AOR-376). 
Summary. Section 305.026(a) of the Government Code places restrictions on the 
use of political subdivision funds to compensate a person who communicates with 
legislative officers or employees for the purpose of influencing legislation. 
Those restrictions do not apply to a political subdivision's payment of dues to 
an organization that uses the dues to pay a registered lobbyist.
EAO-339. Questions about the application of the Judicial Campaign Fairness Act 
to individuals seeking to fill vacancies in judicial offices. (AOR-377).
Summary. For purposes of calculating the fundraising period under 
sec.253.153(a)(1)(B) of the Election Code, a vacancy occurs on the date provided 
by sec.201.023 of the Election Code. A judicial candidate nominated under 
sec.202.006 of the Election Code to fill a vacancy in an unexpired term at the 
November general election may accept political contributions until 120 days 
after the November general election, regardless of whether the candidate has an 
opponent in the November election.
Issued in Austin, Texas, on August 22, 1996.
TRD-9612370
Tom Harrison
Executive Director
Texas Ethics Commission
Filed: August 23, 1996