Untitled Texas Attorney General Opinion

.. . NEY GENERAL, CD EXAS L%US’X’IN. TEXAS 787 CHAWFORD c. XARTlN AlTORNEY #3&NsmzAl- February 13, 1970 Honorable Robert S. Calvert Opinion No.M-573 Comptroller of Public Accounts State of Texas Re: Can new owner of Austin, Texas store operate until current license expires without a transfer of same on Comptrollerls records, and does Comptrollerhave author- ity to transfer store license when presented after its expiration Dear Mr. Calvert: date? By recent letter you request of this office an opinion upon the following stated facts and questions: In the case of Hurt et al vs. Cooper et al, 110 S.W.2d 896, the Court reached the conclusion that the Store-Tax Law I.e. Chapter 17, Title 122A, Taxation-General,V.A.T.S. was an occupa- tion tax. The Comptrollerallowed a transfer of the Current License where a firm was purchased during the year to the new ownership. Cur opinion is requested on the following: 1. Can the new owner operating the purchased place of business continue to operate under the old owners license for the current year without the cur- rent license being transferredon the Comptroller's record prior to expiration. 2. Does the Comptrollerunder the Store Tax Law have the authority to transfer a Store License when presented after the expiration date of the license. -2731- Honorable Robert S. Calvert, Page 2 (M- 573) The Texas Supreme Court case referred to by you, Hurt et al. v. Cooper et al., 130 Tex. 433, 110 S.W.2d 896 (1937), definitely established that our original Chain Store Tax Law* as then com- piled in Article lllld of Vernon's Annotated Penal Code of Texas, was a constitutionallyvalid levy of occupationtaxes, although denominated therein as license fees. The principle relied upon by such Court to sustain this was their determinationthat the primary purpose of the fees provided in such statute was raising of revenue and not regulation. This occupationtax law, substantiallyunchanged, was carried forward as Chapter 17, Title 122A, Taxation-General V.C.S. in a rearrangementof certain of the taxation statutes by the 56th Legislatureat its Third Called Session in 1959. Articles 17.01 - 17.06 of said Chapter 17 provide require- ments for licenses; applicationsand fees for stores and mer- cantile establishmentscoming within the purview of said Chapter, but no provisiohs are set out for the transfer of a license from the original licensee to a subsequent purchaser of the business. Neverthelessthis particular transactionIs provided for in Articles 7055 and 7056, of Vernon's Civil Statutes. Such statutes are in par1 materia with the occupationtax law in question, and they must be,construed with reference to each other. said Arti- cles appear as follows: "Art. 7055. Any person, firm, corporation, or associationof persons, who shall be the legal owners or holders of any unexpired occu- pation license issued in accordance with the laws of this State, may transfer the same on the books of the officer by whom the same was issued. Acts 1885 p.27; G.L. vol. 9 p.647." “Art. 7056. The assignee or purchaser of such unexpired occupation license shall be author- ized to pursue such occupationunder such unexpired license for 'andduring the unexpired term thereof, provided that such assignee or purchaser shall, before following such occupation,comply in all other respects with the requirementsof the law provided for in the original applicationsfor such licenses. Nothing in this law shall be so construed as to authorize two or more persons, firms, corpora- tions or associationsof persons to follow the same occupation under one license at the same time. When- ever any person, firm, corporationor association -2732- , . Honorable Robert S. Calvert, Page 3 (M- 573) of persons following an occupation shall be closed out by legal process, the occupationlicense shall be deemed an asset of said person, firm, corporation or associationof persons, and sold as other prop- erty belonging to said person, firm, corporation,or association;and the purchaser thereof shall have the right to pursue the occupation named in said license, or transfer it to any other person; provided, such occupation license shall under no circumstancesbe transferredmore than one time." A full compliancewith'the requirements of the law pro- vided for in the original applicationsfor such licenses," as required of the purchaser or assignee by said Art. 7056, would seem to be reasonably satisfied by the purchaser or assignee of such unexpired license making an application or request to the Comptrollerfor a recognition of a valid transfer or assignment of such license, giving the Comptrol- ler the informationrequired by him to determine the identity and qualificationsof the new holder of the assigned license and the name and location of the business or businesses to be operated by such assignee. However, we fail to find any pro- visions of said statutes authorizing the Comptrollerto force the new owner to make such application or request, nor can we find any penalty specificallyprescribed for failing to make such application or request. It should be observed that the application or request by the new owner by purchase or asslgn- ment for transfer of an unexpired license is not the aoplication contemplatedor required by said Article 17.02 for the issuance of an original license. We are not authorized to enlarge the scope of said Article 17.02 so as to make it comprehend a request or applicationgrowing out of an assignment or transfer of an unexpired license. See Attorney General Opinion No. o-1673 (19391. On the particularpoint raised by your question No. 1, we find the holding in the early case of Faulkner et al v. Cassidy, 87 S.W. 904 (Tex.Civ.App.1905 err.ref.) to be strongly persuasive if not controlling. In this case the failure of a purchaser of an unexpired liquor license to have the transfer made on the books and to file an applicationdesignatingthe particular house in which he proposed to conduct his business, and to have such designationmade in the license, did not render his bona void. The statutes then in effect concerning the transfer of occupation licenses were identical in terminol- ogy with Articles 7055 and 7056. The Court stated in Its opinion that: "The criterion by which the validity of the bona In such cases is to be determined seems to -2733- . . Honorable Robert S. Calvert, Page 4 (M- 573) be, would the license under which the liquor dealer sold protect him from a criminal pros- ecution for selling liquor without a license?" In holding the transferredlicense in question to be valid in the face of non-compliancewith the statutes con- cerning the transfer of such license, the recording of same on the books of the officer by whom it was Issued and non- compliance in other respects with the requirementsof the law provided for ln the original applicationfor such license, the Court, in Faulkner v. cassiay (supra) in effect, ruled that such requirementsare merely directory and not of such dignity or import as to vitiate the rights otherwise confer- red by such statutes on the purchasers or assignees of such unexpired licenses transferredfor the first time. In view of the foregoing, it is our opinion that the cogent reasoning of such authority is applicable and decisive of the matter posed in your first question, and such question is thereby answered in the affirmative. All licenses issued to operate stores or mercantile establishmentsin this State pursuant to said Chapter 17, expire by the terms of Article 17.04 on the thirty-firstday of December of each year, and on or before that date the holders thereof are required to apply for renewal licenses for the next ensuing calendar year. Any holder of such a license which was assigned to him during the current year, who seeks to have such license duly transferredon the Comptrollerlsrecords during the time the law provided for him to seek a renewal thereof, is entitled to such transfer, and the Comptrolleris authorized to make the same on his records. Penalties are provided by Article 17.04 if applicationsare made after such due date, or not made at all, There is also prescribed in Article 17.09 of said Chapter 17, Title 122A a criminal misdemeanorpenalty for anyone operating such stores or mercantile establishmentswith- out having displayed in a conspicuousplace in such store or mercantile establishmentthe license fee receipt for the current year. It is apparent from the foregoing that the Legislature in enacting the provisions contained in said Articles 17.02 and 17.04 regarding fees and/or penalties for belated or omitted original and renewal applications,had the purpose of collection of revenue rather than regulatorymeasures foremost in mind, and thereby gave the Comptrollerwide powers and authority in the exercise of his duties to collect such taxes and civil penalties. -2734- . . Honorable Robert S. Calvert, Page 5 (M-573) Unlike a strictly regulatory occupation tax, there are no express provisions in said Chapter 17, Title 122A, for the forfeiture of a license. On the contrary the entire thrust of the statutes seem to require the holding of a license by all who come within the purview of this law. In view of the clear mandate of the statutes in question to the Comptrollerto secure license fees from all such store operators, whether or snotapplication is made by such store operators, it reasonably would appear to follow that the Comp- troller, after collecting the fees and penalties, if any due, shall then issue renewal licenses to such store operators. This necessarily entails the recognizingand recording of a license transfer previously made by the original licensee to the present store operator, in order to issue a proper renewal license. This is so regardless of how late the application or request is made, or whether, in fact, it is made at all, but the Comptrolleris not empowered to waive the civil penalties accruing by virtue of the recalcitranceof such store operator. It may be pointed out here that the actual transfer of a right or privilege to conduct the business under the original current license necessarily occurs before the license expires. This is done by the seller at the time he assigns the license to the purchaser. It is only the recording of such previous transfer that remains to be done by the Comptroller. If the Comptroller determines that no such transfer occured, then he can issue only anyoriginal license to the applicant upon the payment of the pro- per fees. It is in this sense that we consider the matters in- volved in this second question. Therefore, your second question is also answered in the affirmative. A person can purchase a business operated under an occupation license issued pursuant to Chapter 17 of Title 122A, Taxation-General, Vernon's Civil Statutes, and operate same until the license expires without such transfer being recorded in the Comptroller'srecords for the current year, provided such license is trans- ferred or assigned to the purchaser along with -2735- Honorable Robert S. Calvert, Page 6 (M-573) _,. i the business; and the Comptrollerhas the author- ity to recognize and record such transfer in his records after the expiration of s* license. s y General of Texas Prepared by R. L. Lattlmore Assistant Attorney General APPROVED: OPINION COMMITl'EE Kerns Taylor‘,Chairman W, &. Allen,-,-Acting Co-Chairman Steve Hollahan Say Floyd Charles Lind cartml Lary Meade F. Griffin Staff Legal Assistant Alfred Walker Executive Assistant Nola White First Assistant Attorney General -2736-