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HomeMy WebLinkAbout80-017 GresimerTO: DISCUSSION: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 John D. Gresimer, Esquire 58 East Fourth Street Emporium, PA 15834 March 12, 1980 Opinion # 80 -017 RE: Local Certified Public Accountant Serving as a Tax Collector FACTS: On August 24, 1979, John D. Gresimer, Attorney for the Cameron County Earned Income Tax Bureau, wrote this Commission asking if a CPA with a small accounting practice could also serve as a tax collector for the local earned income tax bureau. He advised that the tax collector processes the local income tax returns amounting to 1% of the tax payers income. The collections are then despursed to the local municipalities and school districts, as a 5% fee to the tax collector. The tax collector's records are audited by another independent certified public accountant. The issue is whether a local certified public accountant may serve as a tax collector, or whether such services per se conflict in interest under Section 1 of the State Ethics Act. We note that a tax collector is covered by the State Ethics Act as a public official by virtue of the Section 2 definition. This would include coverage of persons appointed to an elected office. A conflict of interest exists when an individual represents two or more persons who have an interest adverse to eachother. A certified public accountant has an obligation to maximize his or her client's interest under the tax laws, while a tax collector has responsibility to maximize the interests of the governmental body which he or she represents. While the preparation of an earned income tax form is purely ministerial, and incidental to the regular work done by a CPA, we hold that a tax collector should not prepare tax forms for clients in his private business which he or she receives as tax collector. Gresimer March 12, 1980 Page 2 CONCLUSION: PJS /alf -2 A local certified public accountant may serve as an earned income tax collector as long as he does not complete or assist in completing income tax returns that he receives. Pursuant to Section 7(9)(i), this opinion is a complete defense in any enforcement proceeding initiated by the Commission and evidence of good faith conduct in any other civil or criminal proceeding, providing the requestor has disclosed truthfully all the material facts and committed the acts complained of in re- liance on the advice given. This letter is a public record and will be made available as such. ` J. /Smit Chairman;