Untitled Texas Attorney General Opinion

QBfficeof tfie !Zlttornep@eneral &date of Qexae DAN MORALES ATTORSEY CESERAL October 7,1993 Mr. Jack W. Garison Opiion No. DM-259 BxecutiveDirector Texas Department of Licensing Re: Whetheramemberofanappraissl and Beg&ion review board may appear before the P.O. Box 12157 boardeitherinacapachyasawurt- Austin, Texas 78711 appointed receiver or a registered property tsx we without violsthtg Honorable Mike Driscoll con&t-of-intmst laws and related Harris County Attorney questions (BQ-507, JD# 18811) 1001 Preston, Suite 634 Houston, Texas 77002 Dear Mr. Garison and Mr. Driscotl: Eachofyouhas~ustodetamineametheramrmberofMappraisalmiew board or an appraisal district board may paform certain professional services. Mr.Driswll asks whether a member of an apprsissl review board may repmsem a taxpayer in connection with the valuation of a certain tract or parcel of land in the board member’scapacity as a court-appointed receiver of the same tract or parcel of land. Mr. Garison a&s whether an appraisal review board member may pet%ormproperty tax consulting services, in the ssme or a ditferent appraisal district, without violating contlict- of-interest laws. Mr. Garison also a&s whether an appraisal district board member may perfom property tax consulting servicq either in the ssme or a different appraisal district. An appraisal review board generally consists of three members, Tax Code 4 6.41(b), who meet to exsmine and approve appraisal records that the chief appraiser hss submitted to the appraisal review board. Id 58 6.42(b), 41.01. Section 41.41 of the Tax Code provides a property owner with a right to protest several hinds of actions before an appraisal review board: (1) determinstion of the appraised value of the ownefs property or, in the case of land apprsised as provided by Subchapter C, D, or E, Chapter 23, determinstion of its appraised or msrhet value; (2) unequal apprsissl of the owner’sproperty; (3) inclusion of the own&s property on the appraisal records; (4) denial to the property owner in whole or in psrt of a partial exemption; p. 1345 Mr. Jack W. Gsrison - Page 2 (DM-259) Honorable Mike Driscoll (5) determination that the owner’s land does not qualify for appraisal as provided by Subchapter C, D, or E. Chapter 23; (6) identification of the taxing units in which the ownet’s property is taxable in the case of the appraisal district’sappraisal roll; (7) determination that the property owner is the owner of property; (8) a determinauon that a change in use of land appraised under Subchapter C, D, or E, Chapter 23. has ocaured, or (9) any other action of the chief appraiser, appraisal district, or appraisal review board that applies to and adversely affects the property owner. See ah id. $8 41.411, 41.42, 41.43. Following notice and a hearing, see id. $5 41.45, 41.46. 41.461, the appraisal review board must determine the protest and, if necessary, correct the appraisal records to conform with its determination. See id. $41.47(b). Mr. DriscoU asks about the propriety of an appraisal review board member mpment& a taxpayer in a capacity as the court-appointed receiver of the taxpayer% property, which lies in the appraisal review board’sjurisdiction. Jn his brief, Mr. DriscoU CXplGlS: A receiver holds property for the be-n&t of the owner and the receivds actions are generally in accordance with the best interests of the property owner. The receiver is also entitled to reasonable compensation for his services as receiver. . . . In the situation at hand, the member bad been appointed receiver by the judge of the 247th District Court of Harris County, Texas[,] in 1984. The judge of the 247th ordered that the receiver sell the property using “prudent real estate practices” and that the proceeds be distributed between the husband and wife. Subsequently, the receiver was appointed to serve on the Harris CountyAppraisalBeviewBosrdin1989andagainin 1991.. . On December 9, 1992[,] the property owner notified the appraisal district that the review board member would be handling [a] protest and withdrew his approval of the 1992 market value which had previously been settled with a district appraiser. Footnote omitted.] p. 1346 Mr. Jack W. Garison - Page 3 (DM-259) Honorable Mike Driscoll Mr. Driscd particularly asks about the applicabiity of section 6.412(a) of the Tax Code and section 36.08 of the Pensl Code. Under section 6.412(a) of the Tax Code, an individualis ineligiblefor service on an appraisal review board if the individual is “related within the second degree by consanguinity or affhdty, as determined under Article 5996h, Revised Statutes,1 to an individual who is engaged in the business. . of representing property owners for compensation in proceedings under this title in the appraisal district for which the appraisal review board is established.” (Footnote added.) The legislature enscted section 6.412(a) in 1989. see Acts 1989, 71st Leg., ch. 796. 4 12. at 3595, and amended the subsection in 1991 by adding the language “as determined under Article 5996h, Revised Statutes,”see Acts 1991,72d Leg., ch. 561, Q45, at 1988. Former article 559611,V.T.C.S., see slrpro note 1, which the legislature also enacted in 1991 by the passage ofHouse Bill 1345, see Acts 1991,72d Leg., ch. 561, Q 1. at 1979-80-&e same bii that amended section 6.412(a) of the Tax Code-provides that relationships by wnsanguinity or aflinity must be determined using the civil Jaw method. See Gov’t Code 8 573.021. The Government Code provides for the calculation of degree of relationship as follows: Sec. 573.022. (a) DETERMINATJON OF CONSANGUIN- ITY. Two individualsare related to each other by wnsanguinity if: (1) one is a descendant of the other, or (2) ifthey shsre a wmmon ancestor. . . . Sec. 573.023. (a) COMPUTATION OF DEGREE OF CON- SANGUINITY. The degree of relationship by wnsanguinity between an individual and the individual’sdescendant is determined by the number of generations that separate them. A parent and child are related in the first degree, a grandparent and grandchild in the second degree, a great-grandparent and great-grandchild in the third degree and so on. . . Sec. 573.024. (a) DETERMINATION OF AFFINITY. Two individuals are related to each other by affinity if: (1) theyaremsrriedtoeachother;or ‘In 1993 the .ticven@tird Legislah~t repealedV.T.C.S. Miclc S9%h. See Acts 1993, 73d l&g., ch. 268. The lnamial in thatsrlicle was oxiitied as chspter573 ofthc Gavcrnmentcnde. p. 1347 Mr. Jack W. Carbon - Page 4 (DM-259) Honorable Mike Driscoll (2) the spouse of one of the individuals is related by wnsanguinity to the other individual. By definition, the determination of degree of a relationship by wnsanguinity or by athnity assumes a relationship between twopersons. Thus, for purposes of calculating the degree of a relationship by wnsanguinity or by &My, a person may not be related to hhnself or herself We do not believe the legislature envisioned that section 6.412(a) of the Tax Code would apply to a situation in which a member of the appraisal review board is the “individual who is engaged in the business. . . of representing property owners for wmpensation in proceedings under this title in the appraisal district for which the appraisal review board is established.” See also infra note 11 and accompanying text (describing legislative history of Tax Code section 6.035(a)). Jn our opinion, therefore, section 6.412(a) of the Tax Code is inapplicableto the situation before us here.2 Additionally, section 36.08 of the Penal Code is inapplicable. Section 36.08 prohibits gifrs to public servants in ceriain circumstances; it does not prohibit a public servsnt from receiving adequate compensation for services the individualperformed in an unofficial capacity. See Penal Code $5 36.08, 36.10(a)(l). See genera&v Attorney Generd Opinion H-551 (1975). We believe that section 41.69 of the Tax Code governs this situation. Section 41.69 precludes a member of an appraisal review board from participating in the determination of certain taxpayer protests: A member of the appraisal review board may not participate in the determination of a taxpayer protest in which he is interested or in which he is related to a party by atlinity within the second degree or by wnsan8uinity within the third degree, as determined under Article 5996h, Revised Statutes.3 Footnote added.] The legislature added section 41.69 to the Tax Code in 1979. See Acts 1979,66th Leg., ch. 841, Q 1, at 2309. To fully answer your question, we must deduce the meaning the legislature intended when it used the word “interested” in section 41.69 of the Tax Code. 2Suxion 41.69 nf the Tax CQ& pmhibils P member of an appmial review bard from psrtioipaing in the determinationof a tapnyu protestin which the memberpusonally is intaemd or in which the memberis mlated within a prohiiiteddegreetc a parryh&vat to the pmtest. See infio (qootiq Tax Gxk @on 41.69). Clearly,ifthe legislatun wantedto write section 6.412(a) to apply to a situation in which the appraisalreview boardmemberwas personallyim~lvcd as well as a situation in which the memberwas mlatedto an individualrqescn~ proper&ownersbeforethe appraisalreview bosrd,the legislatotecould have done so. p. 1348 Mr. Jack W. Garison - Page 5 (DM-259) Honorable Mike Driscoll U~&or&unately, we found no legislative history indicating the kinds of situations in which the legislature envisioned that an appraisal review board member might have an interest in a taxpayer protest. We look, therefore, to similar wnstitutionsl and statutory provisions in existence in 1979, of which we presume the legislature was aware. See Attorney General Opiion V-1215 (1951) at 2. The majority of the provisions we exsmined, however, modify the word “interest” in such a way as to affect the interpretation of the provision. See, e.g., Tex. Con.% art. III, 5 18 (prohibiting legislator from being “interested, either directly or indirectly” in certain contracts with state), art. III, $22 (requiring legislator with “personal or private interest” in proposed legislation to disclose interest and refrain from voting on proposal); Gov’t Code 5 573.058(a) (requiring state board or commission member with “personal or private interest” in matter before board to disclose interest and to refrain f?om voting on matter); Local Gov’t Code 5 81.002 (requiring newly appointed wunty judge or county commissioner to at&-m that he or she “will not be interested, directly or indirectly” in wntract with or claim against county). We found one provision, article V, section 11 of the Texas Constitution, that uses the word “interest”without any attendant modifiers, and we believe this provision and the judicial interpretation of this provision are instructive for our purposes here. Article V. section 11 forbids a judge from sitting in any case in which the judge “may be interestad,. . . or when he shall have been counsel in the case,” among other things. “Interest”has been construed to refer to a direct personal or pecuniary interest in the case. See Tex. Cons&art. V, 5 11 interp. commentary; City of Oat Cltflv. Stoe, 79 S.W. 1068, 1069 (Tar. 1904) (and cases cited therein); Attorney General Opiion DM-109 (1992) at 34 (and cases cited therein). We accordingly interpret section 41.69 of the Tax Code to apply whenever a member of an appraisal review board has a direct personal or pecuniary interest in the determination of a taxpayer protest before the appraisal review board. In our opinion, a member of an appraisal review board who, as a paid, court-appointed receiver, is representing a taxpayer in a protest before the appraisal review board has, as a matter of law, a direct personal or pecuniary interest in the result.4 Section 41.69 of the Tax Code accordingly precludes the membe?s participation in the appraisal review board’sdetermination of the protest. p. 1349 Mr. Jack W. G&on - Page 6 (DM-259) Honorable Mike Driscoll We note that chapter 171 of the Local Government Code also may apply in this situation. Chapter 171 of the Local Government Code, which regulates wnflicts of interest of local public official-$including a member of an appraisal review board, requires a local public official, prior to a vote or decision on any matter involving a business entity or real property in which the official has a substantial interest, to disclose the nature and extent of the interest. Local Gov’t Code 5 171.004(a); see 35 D. BROOKS,COUNTYAND SPECIALDl8TRRXLAW 8 18.37, at 632-33 (Texas Practice 1989). Jn certain specified circumstances, the official also must abstain from tbrther participation in the matter.6 Id. Chapter 171 of the Local Government Code expressly preempts common-law wntlictsf- interest rules as they apply to local public officials. Local Gov’t Code 6 171.007(a); see also Attorney General Opinions JM-1187 (1990) at 4; JM-424 (1986) at 4. Under chapter 171 of the Local Government Code, an official has a substantial interest in a business entity if (1) the person owns 10 percent or more of the voting stock or shares of the business entity or owns either 10 percent or more or SS,CMM or more of the fair market value of the business entity; or (2) 5nds received by the person gem the business entity exceed 10 percent of the person’sgross income for the previous year. Local Goti Code 5 171.002(a); see also Anomey General Opiion JM-.I187 at 2-3. Notably, section 171.004(a) of the Local Government Code applies to any local public official who has a substantial interest in a business entity or real property that is involved in a matter before the governmental body. On the other hand, section 41.69 of the Tax Code applies only to members of an appraisal review board, but it applies to a taxpayer protest in which a member has a direct personal or pecuniary interest, regardless of the quantity of the interest. Thus, if a member of an appraisal review board is interested in a particular taxpayer protest before the board but that interest is not a “substantial interest” Section 171.001(l) oftbe Local GovermnemCode detines “localpublic of&id’ as .a member bodyoranotherofliax,wbelherelected,appointed,paid,orun@d,ofany iist% .?z? . exerch responsibilitiesbeyondthose that am advisoryin nahue.” %ection 171.004(a)(l) quires a local public o5icial lo abstainfrom participationin a matter kforcthgovcnunentalbodyofwhich(heofficialisamemkrifthcoff~cialhasasubstantialintaatina budacssentity,and”actionmthemancrwill~aspecialeconomic~:eamthcbusinmmtitythatis distinguishble from the tied on the public.” See infro (dclining “sobstantialinter&). Similarly, section 171.004(a)(2)mquiresa local public official to abstain from participationin a matterbefore the gwanwntal~ofwhichthofflcialiramcmbcriftbc~~hara~intcrcninrtal pmperly,sod ‘it is reasonablyforeseeablethat an actionon the matterwill have P special economiceffect on lbe value of lhe property,distinguishablefromits e&cl on the public.’ Id. (same). Failure to comply with the requirementssection 171.004 articulatesmay am&uIe a class A mi2demeanor.Local GJVVcode 0 171.003. p. 1350 Mr. Jack W. Garison - Page 7 W-259) Honorable Mike DriscoU within the context of chapter 171 of the Local Government Code, section 171.004(a) authorizes the member to participate in the determination of the protest, while section 41.69 of the Tax Code prohibits the members participation. Additionally, even if the member has a substantial interest, section I71.004(c) may authorize the member to participate after disclosingthe nature and extent of the interest, while, & section 41.69 of the Tax Code prohibits the member’s participation. To the extent of any wnflict between section 171.004(a) of the Local Government Code as it applies to a member of an appraisal review board and section 41.69 of the Tax Code, section 41.69 prevails because it applies specificsUyto members of an appraisal review board. See 67 TEX. JUR 3d Stitufes 8 126. at 719-24 (explaining that if general provision of statute irreconcilably wnflicts with special or local provision, special or local provision generally prevails); id. 8 136, at 752 (stating that if general statute and more detailed enactment conflict, latter generally prevails). Mr. G&son’s questions involve a registered property tax wnsuhant. Article 8886, section 2(d)(7), V.T.C.S., authorizes a registered property tax wmukant to perform or supervise the performance of the following services: (A) preparing a property tax rendition or report for another person under Chapter 22, Tax Code; (B) representing another person in a protest under Subchapter C, Chapter 41, Tax Code; (C) wnsuhing or advising another person wnwming the preparation of a property tax rendition or report under Chapter 22. Tax Code, or wncerning a matter the person may protest under Subchapter C. Chapter 41. Tax Code; (D) negotiating or entering into an agreement with an appraisal district on behalf of another person wnceming a matter that is or may be the subject of a protest under Subchapter C, Chapter 41, Tax Code; or Q acting as the designated agent of a property owner in accordance with Section 1.111, Tax Code.7 V.T.C.S. art. 8886. 0 I(a)(7) (footnote added; footnote deleted). An appraisal review board hears matters protested under subchapter C, chapter 41 of the Tax Code. See id. 5 l(a)(7)(C). Thus, a property tax wnsultsnt will have occasion to represent taxpayers before an appraisal review board. 7Scaionl.llldthcTaxCodcauthorizerapmpcrty-tode+i~~apasonu,rctast& owner’s agent for any purpose under title 1 of the Tax Code (chapters l-43) in ameuion wi(h the propertyor propertyownerand providesthe m&cd by which a property- may so designate. p. 1351 Mr. Jack W. Garison - Page 8 (DM-259) Honorable Mike Hriscoll Initially, Mr. Garison asks whether a registered property tax wnsultsnt may serve as a member of an appraisal review board.* We are unaware of any statutory or wmmon- law provision that prohibits a registered property tax wnsultant from serving as a member of an appraisal review board. Of wurse, section 41.69 of the Tax Code limits a member’s participation in a taxpayer protest in which the member has a direct personsl or pecuniary interest. In our opinion, a member of sn appraisal rev& board who performs property tax consulting services in a taxpayer protest that is before the appraisal review board has, as a matter of law, a direct personal or pecuniary interest in the outcome of the matter. Accordingly, section 41.69 of the Tax Code prohibits the member’sparticipation in the determination of the protest.9 Neither section 41.69 nor any other law of which we are awsre limits a member of an appraisal review board from performing property tax wnsulting services before an appraisalreview board of snother district, however. Mr. Garison also asks whether a registered property tax wnsuhant may serve as a member of an appraisal district board, and conversely. whether a member of an appraisal district board may perform property tax wnsulting services, in the ssme or a ditferent appraisal district, without violating wntlict-of-interest laws.rO Section 6.01(a), (b) of the Tax Code establishes in each county an appraisal district, which has the responsibility of appraising property in the district for ad vulorem tax purposes of the taxing units in the appraisal district. See Tax Code 6 1.04(12) (defining “taxing unit”); see also Attorney Generd Cpiion JM-3060 (1989) at 1. A five-member board of directors governs each appraisal district. Tax Code 4 6.03(a); see also Attorney General Opiion JM-1060 at 1. The duties of the appraisal district board are largely administrative; for example, the appraisal district board must appoint a chief appraiser, who serves as the chief administrator of the appraisal office, Tax Code 8 6.05(c), and approve an annual budget for the appraisal district, id. 8 6.06. Members of the public may wmment on any issue *A0 wt amoider all nf Mr. Oarimn’sqwsUon9, we me a- that article 8886, section 6(a), V.T.C.S.. reqdms the wmmimioner of licensing and regulation to “establish standa& of practice, condw4 snd ethico” for registeredpmpertytax con&ants. Title 16, se&on 66.20(f) of the Texas Mminidrativecode~ulatathecodeofahicstowhichcschngistrrcdpropertytax~~mmust submit. Tbecodeofcthics~contDinraoprwisionrthatapplyto~ofthcrituationraboutwhich Mr. Oarioon asks IO nor opinion, bownm, anick 8886, section 6(a). V.T.C.S., authorizes UK commissi~ to promulgatesuch pmvisions. 9Forthcreasonsstated~,wcQnocw~dat&applicabilityofchapal7loftbcW Ooemmal Cnde. See swprowtcs 5,6 mui accompanying text (discussing chapter 171 and ampring Gavcrnaent Codesection 171.004(a)tithTaxCodesection41.69). l”Additionally,Mr. G&son asks whdher the state eIhics law, Oovemment Code chap&r 572, formerlyV.T.C.S. akcle 6252~9b.Acts 1993,73d Leg., ch. 268.0 1,46, pmhiiits a memberofeilher an appraisaldiariaboardoran~praisalrcvicwboardfromprfonningpropcrtytaxwnsulting~~ia lhe same or a di&mnt dihct, or wnvcrscly, a r@tered pmperIytax wnsultant from serving on either board. The otstc ethics law applies only to slaIe officers and state employeesee Gov’tCode $572.001 (formerlyV.T.C.S. art. 6252~9b,8 1); it does not apply, therefore,to a memberof an appraisaldislricl bC4Ud0rflp@.9dlCWbOiUd. p. 1352 Mr. Jack W. Garison - Page 9 (DM-259) Honorable M&e Driscoll within an appraisal district board’sjurisdiction, see id. 5 6.04(d), and may 6le complaints with the board, see id. 0 6.04(f). (g). Because a registered property tax consultant is authorized to represent a property owner for any purpose under title 1 of the Tax Code see V.T.C.S. art. 8886, 8 I(a)(7)(E); Tax Code 5 1.11l(a), a property tax consultant may have occasion to represent a properly owner before an appraisal district board. We End no wngict-of-interest law that prohibits a registered property tax wnsuhant from serving as a member of an appraisal district board. Regarding the propriety of an appraisal district board member performing property tax wnsulting services either in the same or a different appraisal district, we note initiaUythat section 6.035(a) of the Tax Code parallels section 6.412(a) by making ineligible for service on a appraisal district board an individual“related within the second degree by wnsan8uinity or silinity, ss determined under Article 5996h, Revised Statutes, to an individual who is engaged in the business. . of representing property owners for wmpensation in proceedings under this title in the appraisal district.” The legislature enacted section 6.035(s) by mews of the same bii that enacted section 6.412(a). See Acts 1989. 71st Leg., ch. 796, 8 4, at 3592. The legislature subsequently amended section 6.035(a) expressly to reference article 599613 V.T.C.S., by means of the same bii similarly amending section 6.412(a). See Acts 1991, 72d Leg., ch. 561, 5 43, at 1987. But see supra note 1. For the reasons discussed in connection with section 6.412(a), see stcpra notes l-2 and accompanying text, we believe that section 6.035(a) does not apply to a situation in which a member of an appraisal district board is “an individualwho is engaged in the business of apprsking propetty for compensation for use in proceedings under this title or of representingproperty owners for wmpcnsation in proceedings under this title in the appraisal district.“tr zr Hemiogson H.B.24.95Beforethe HouseSubacun. en Ways& Mesns,71st Leg. (Apr. mement 0fRepmatsnve Vsligura)(rapesvsilsblefromHcuss&aminee 8erviw OfIke). kIdditionoOy,Rqmentstive Vsllgommawted for the mbanamttlcethe drauanaam in Mentgomcry County,whichevidentlypmmptcdhim to iatmdweHouseBit 2495. He wted that th Montgomry ~Ehid~suwasnunorcdto~rrlativsinthcappraisalwwboccdimtErcaivad pmfemtM trcatmcot Id. One of the boardmembers“a. sqportu of IRcpnscntatinValigura’r],* stsohsdavaygmdspprstsslbusinw. Id. RcprcscntativeVsligurafchthstwpencnccmin8before tbeapprairaldimidboardforprotcztorforvpluatioasrbouldreceive~typeofprrfaentiplmatmcnl Id. We believethatRsprescntative Valigura’testtmony s laudsfirrtkr suppcntc ear wnclusionthat &on 6.035(a)cd lhc Tsx Cedeappliescmlyto sttustionsin whicha relativeof a boardmcmk is iovolvedin the appraisalbusiness;the legislsturcdid not intendthe s§ionto spptyin a stmstionin whichtheboardmemberhim&for herselfis involvedin theappraisalbusiness. p. 1353 Mr. Jack W. Garison - Page 10 (DM-259) Honorable Mike Driscoll We believe that chapter 171 of the Local Government Code governs the situation about which Mr. Garison asks.12 Under chapter 171, a member of an appraisal district board must, prior to a vote or decision on any matter involving a business entity or real property in which the member hss a substantial interest, disclose the nature and extent of the interest and possibly to abstain from tinther participation in the matter.‘3 See supra notes 5, 6 and accompanying text (discussing chapter 171 and comparing Gov’t Code # 171.004(a) with Tax Code § 41.69). However, whether, for purposes of chapter 171 of the Local Government Code, a member of an appraisal district board has a substantial interest in a business entity and therefore must comply with section 171.004(a) is a question involving the resolution of facts; such a question cannot be determined in the opinion process. Gn the other hand, we are unaware of any statute that limits a member of an appraisal district board from performing property tax wnsultant services before the appraisal district board of another district. SUMMARY Pursuant to section 41.69 of the Tax Code, a member of an appraisal review board may not participate in the determination of a taxpayer protest before the appraisal review board in which the member, acting as a paid, court-appointed receiver of a tract of property in the appraisal district, represented a property owner becsuse the member has, as a matter of law, a direct personal or pecuniary interest in the outcome of the protest. Siarly, section 41.69 of the Tax Code precludes a member of an appraisal review board from participating in the deterrninstion of a taxpayer protest if the member performed property tax wnsuhing services in the protest RepmmnMvc Valigura’sbill, HouseBii 2495, was left pendingbeforethe damunit& of the HouseCommiltceonWaysandMcans. Howcver,thcHouseChmitteeonWaysandMeansincorporatcd into its wmmittce substiMe for House Bill 432 subrtantiallysimilar language to that House Bill 2495 propodforIhcacws&ion6.035ofUuTaxCdc. Furhnnorc,thcwmmitt~ddutepmpodtbc addition d section 6.412(a) 10 the Tax Code, rhe language of which is atbaaotially similar lo the lwgosge of section 6.035(a). Rqmsatalivc Stila, lhe authorof House Bill 432, wnsi6ered House Bill 432tobe’anomnibusbilltbat...willdeanupthcproblanrofadministration~financingd appmiddiaricIsiathcatatc.’ 12Section41.69 ofthe Tax Code&es not applyIme beta= that sectionapplies to the members ofanapp&salreviewbmrd,noItothcmanbcrsofanappraisaldistriaboard Whis office has 9tatedthat a memberof an appraisaldistrictboardis a local public official for 7 of chapter171 of tie Local GovernmentCode. See AnorneyGeneralOpinion JM-1187(1990) p. 1354 Mr. Jack W. Garison - Page 11 W-259) Honorable Mike Driscoll because the member therefore has a direct personal or pecuniary interest in the determination of the protest. Section 171.004(a) of the Local Government Code requires a member of an appraisal district board who has perfomxd property tsx wnsulting services in a taxpayer protest before the appraisal district board to disclose the nature and extent of the men&z’s interest, but only ifthe member hss a substantial interest in a business entity or real property involved in the matter. The determinstion of whether an appraisal district board member hss such a substantial interest involves the resolution of facts; it is therefore outside the scope of the opinion process. DAN MORALES Attorney General of Texss WILL PRYOR First Assistant Attorney Genersl MARYJCJZLJD Deputy Attorney Genersl for Lit&ion RENEA HICKS State Solicitor MADELEINE B. JOHNSON Chair, opinion Committee Prepared by Kymberly K. Oltrogge Assistant Attorney General p. 1355