| Advisory opinion request regarding post-employment restrictions for an employee of the City of New Orleans. |
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Lynette Doyle served as the Revenue Collector
for the City of New Orleans from April 2024 through January 12, 2026. In that
capacity, she oversaw the Board of Revenue, which was responsible for the collection,
processing and recording of sale taxes, parking taxes, hotel/ motel sales
taxes, and occupational license renewal fees. Her duties included oversight of
the delinquent tax and sales tax audit division. The organizational chart for the City of New Orleans, Department of Finance indicates that the Collector of Revenue was the agency head for the Bureau of Revenue. The Board of Revenue is one of
five bureaus under the Finance Department for the City of New Orleans; thus,
Ms. Doyle's immediate supervisor was Romy Samuel, the Director of Finance for
the City of New Orleans.
Ms. Doyle is considering starting a
business to provide seminars for businesses related to sales taxes such as
applicable tax rates, tax laws, tax exemptions. Ms. Doyle would also provide
back-office accounting and tax preparation work such as calculating the sales
tax liability due and creating sales tax worksheets, reconciliations, and data
analysis. Ms. Doyle's consulting services would include identifying taxable and
non-taxable transactions, applicable exemptions, exclusions, identifying the
correct forms to file, proper record maintenance, and proper completion of tax
returns.
Ms. Doyle does not intend to represent
clients in any capacity before the Bureau of Revenue concerning audit engagements,
administrative hearings, delinquent notices, bank levies, or regular tax filings.
Further, Ms. Doyle will not communicate directly with the Bureau of Revenue on
behalf of any clients, as her clients will bear sole responsibility for
completing, signing, and filing their returns, renewing occupational licenses,
and setting up online payments.
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La. R.S. 42:1121A(1) provides no former agency head or elected official shall, for a period of two years following the termination of his public service as the head of such agency or as an elected public official serving in such agency, assist another person, for compensation, in a transaction, or in an appearance in connection with a transaction, involving that former agency or render any service on a contractual basis to or for such agency.
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| Assigned Attorney: |
Kelsey Simmons |
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