NYSBA 1993-04-01

Can a lawyer co-own a corporation with nonlawyers that helps homeowners win real estate tax reductions and pays out profits by share?

Short answer: The opinion concluded that a lawyer may not form such a corporation: the lawyer conceded the work is the practice of law, so the corporation's furnishing it would violate Judiciary Law Section 495, and splitting the revenue with nonlawyer shareholders would share legal fees with nonlawyers.
Currency note: this opinion is from 1993
Subsequent statutory amendments, court decisions, or later opinions or rule amendments may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.
Disclaimer: Advisory only. Not binding precedent.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official ethics opinion. The original opinion (linked at the bottom of this page) is the authoritative source for any reliance.

NY State Bar Ethics Opinion 644: A corporation with nonlawyers for real estate tax reductions

Short answer: The opinion concluded that a lawyer may not form a corporation with two nonlawyers to assist homeowners in obtaining real estate tax reductions, because the corporation's furnishing of the lawyer's legal services would violate Judiciary Law Section 495 and the share-based distribution of profits would split legal fees with nonlawyers.

Disclaimer: This is an advisory ethics opinion. Advisory opinions are not binding; they interpret the New York State Bar Association's rules of professional conduct and are persuasive authority. This summary is for research purposes only and is not legal advice. Verify current rules before acting on any specific guidance.

About this page: The plain-English summary and Q&A below were written by Ezel based on the official opinion. We do not reproduce the opinion text on this page; follow the linked source for the official text, which controls.

View original opinion

Plain-English summary

A lawyer asked whether he could form a corporation with two nonlawyers to help homeowners obtain reductions in their real estate tax assessments. The lawyer and the two nonlawyers would be the shareholders; the lawyer would be employed by the corporation as counsel to file and submit the tax-reduction petitions, and profits and losses would be distributed in proportion to each shareholder's number of shares.

The committee noted that the inquirer himself acknowledged that filing and submitting the petitions would be the practice of law. Given that concession, the committee explained that the corporation's furnishing of those legal services would violate Judiciary Law Section 495, which bars a corporation from making it a business to practice law or render legal services through lawyers in its employ. Participating in that arrangement would therefore be improper under DR 7-102(A)(8) (a lawyer shall not knowingly engage in illegal conduct) and DR 3-101(A) (aiding a nonlawyer in the unauthorized practice of law). The committee cited People v. Lawrence Preska Assocs. and People v. Peoples Trust Co. for the purpose of Section 495: preventing corporations from interposing themselves in the attorney-client relationship and shifting the lawyer's loyalty to the corporation.

The committee added that even if the arrangement did comply with the Judiciary Law, the profit-and-loss distribution would independently be improper. Because the corporation's revenue would come at least in part from legal services, distributing that revenue among the lawyer and the nonlawyer shareholders would violate DR 3-102(A), which prohibits sharing legal fees with nonlawyers. Quoting N.Y. State 618 (1991), the committee explained that the rule protects a lawyer's independence by preventing nonlawyers from owning an interest in, or having a financial inducement to direct, the practice of law.

Currency note

This opinion was issued in 1993, under New York's former Code of Professional Responsibility, which New York replaced with the Rules of Professional Conduct in 2009. The provisions on the unauthorized practice of law and on sharing fees with nonlawyers have since been renumbered and revised. Subsequent rule amendments or later opinions may have changed the analysis. Treat this page as historical context, not current guidance. Verify against current rules before relying on any specific rule, deadline, or requirement mentioned here.

Common questions

Q: Can a lawyer and nonlawyers co-own a company that provides the lawyer's legal services?

A: No. The committee concluded that where the company furnishes legal services through a lawyer it employs, the arrangement violates Judiciary Law Section 495, and a lawyer may not participate (DR 7-102(A)(8), DR 3-101(A)).

Q: Why was the profit split a separate problem?

A: Because the corporation's revenue came partly from legal services, distributing it to nonlawyer shareholders would share legal fees with nonlawyers in violation of DR 3-102(A), independent of the Judiciary Law issue.

Q: Did the committee decide whether the tax-reduction work is the practice of law?

A: It did not need to. The committee generally does not pass on questions of law, and the inquirer had conceded that filing and submitting the petitions would constitute the practice of law.

Background and rules framework

The opinion interpreted DR 3-101(A) (aiding unauthorized practice), DR 3-102(A) (sharing legal fees with a nonlawyer), and DR 7-102(A)(8) (knowingly engaging in illegal conduct) of New York's former Code, together with Judiciary Law Section 495. The closest Model Rule analogues are Rule 5.4 (professional independence; sharing fees with nonlawyers), Rule 5.5 (unauthorized practice), and Rule 8.4 (misconduct). New York replaced the Code with the Rules of Professional Conduct in 2009; the provisions cited here are historical.

Citations and references

Rules of Professional Conduct:

  • MR 5.4 (professional independence of a lawyer; sharing fees with nonlawyers)
  • MR 5.5 (unauthorized practice of law)
  • MR 8.4 (misconduct)
  • NY DR 3-101(A), DR 3-102(A), DR 7-102(A)(8)

Statutes:

  • N.Y. Judiciary Law Section 495 (corporations practicing law)

Cases:

  • People v. Lawrence Preska Assocs. Inc., 90 Misc. 2d 59, 393 N.Y.S.2d 650 (1977): purpose of Section 495
  • People v. Peoples Trust Co., 180 A.D. 494, 167 N.Y.S. 767 (1917): purpose of Section 495

Other opinions cited:

  • N.Y. State 618 (1991): purpose of the rule against sharing fees with nonlawyers

See also

Source