U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

99–006 

" ! HOUSE OF REPRESENTATIVES 

112TH CONGRESS

1st Session 

REPORT

2011

112–193 

House Calendar No. 67 

IN THE MATTER OF ALLEGATIONS 

RELATING TO MICHAEL COLLINS 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 5, 2011.—Referred to the House Calendar and ordered to be 

printed 


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(II) 

COMMITTEE ON ETHICS 

JO BONNER, Alabama 

Chairman 

MICHAEL T. MCCAUL, Texas 

K. MICHAEL CONAWAY, Texas 

CHARLES W. DENT, Pennsylvania 

GREGG HARPER, Mississippi 

LINDA T. SA ́ NCHEZ, California 

Ranking Member 

JOHN A. YARMUTH, Kentucky 

DONNA F. EDWARDS, Maryland 

PEDRO R. PIERLUISI, Puerto Rico 

JOE COURTNEY, Connecticut 

REPORT STAFF

DANIEL A. SCHWAGER, Chief Counsel/Staff Director 

DEBORAH SUE MAYER, Director of Investigations 

KELLE A. STRICKLAND, Counsel to the Chairman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

CLIFFORD C. STODDARD, Jr., Senior Counsel 

CHRISTOPHER R. TATE, Counsel 


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LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, August 5, 2011. 

Hon. KAREN L. HAAS, 

Clerk, House of Representatives, 

Washington, DC. 

DEAR MS. HAAS: Pursuant to clauses 3(a)(2) and 3(b) of rule XI 

of the Rules of the House of Representatives, we herewith transmit 

the attached Report, ‘‘In the Matter of Allegations Relating to 

Michael Collins.’’ 

Sincerely, 

JO BONNER, 

Chairman. 

LINDA T. SA ́ NCHEZ, 

Ranking Member. 


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C O N T E N T S 

Page 

I. Introduction ...................................................................................................... 1 

II. House Rules, Laws, Regulations, or Other Standards of Conduct ............... 2 

III. Background ....................................................................................................... 3 

IV. Findings and Conclusions ................................................................................ 6 

V. Statement Under Rule 13, Clause 3(c) of the Rules of the House of 

Representatives ............................................................................................. 7 

Appendix A: Report and Findings of the Office of Congressional Ethics Regarding Michael Collins (Review No. 11–4518) ................................................. 8 

Appendix B: Michael Collins’ Response to the Report and Findings of the 

Office of Congressional Ethics ............................................................................. 90 


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1OCE’s Report and Findings regarding Michael Collins, Review No. 11–4518, can be found 

at Appendix A. 2Michael Collins’s response to OCE’s allegations against him in OCE’s Report and Findings 

can be found at Appendix B. 3 House Rule XI, clause 3(b)(8)(A), and Committee Rule 17A(c)(1). 

112TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 1st Session 112–193 

COMMITTEE ON ETHICS 

IN THE MATTER OF ALLEGATIONS RELATING TO 

MICHAEL COLLINS 

AUGUST 5, 2011 

Mr. BONNER, from the Committee on Ethics, 

submitted the following 

R E P O R T 

I. INTRODUCTION 

On May 18, 2011, the Office of Congressional Ethics (OCE) forwarded to the Committee on Ethics (Committee) a Report and 

Findings related to the receipt of outside income in 2007, 2008, and 

2009 by Michael Collins, which he failed to properly report on his 

2009 federal income tax returns and his 2007, 2008, and 2009 Financial Disclosure Statements.1 OCE further indicated in its referral that Mr. Collins received income in 2009 that exceeded the outside earned income limit for senior staff. OCE recommended that 

the Committee further review the matter. 

On May 23, 2011, the Committee provided Mr. Collins, through 

his attorney, a copy of OCE’s Report and Findings and offered him 

the opportunity to respond to OCE’s allegations. Mr. Collins submitted a response through his attorney on June 9, 2011.2

The Committee initiated an investigation into the matter referred by OCE pursuant to Committee Rule 18(a). On July 1, 2011, 

the Chairman and Ranking Member of the Committee issued a 

statement announcing they had jointly decided to extend the Committee’s consideration of OCE’s transmittal regarding Mr. Collins 

for an additional 45-day period.3

This Report, adopted by the Committee on August 1, 2011, resolves the matter forwarded by OCE. The Committee has unaniVerDate Mar 15 2010 13:21 Nov 18, 2011 Jkt 226001 PO 00000 Frm 00007 Fmt 6659 Sfmt 6602 E:\HR\OC\HR193.XXX HR193

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4 5 U.S.C. app. 4 § 101(d). 

5 5 U.S.C. app. 4 § 102(a). 

6 5 U.S.C. app. 4 § 104. 

7 5 U.S.C. app. 4 § 501(a)(1). 

8Memorandum from Committee on Standards of Official Conduct for All Members, Officers, 

and Employees, dated February 12, 2009 (emphasis in original). 

mously determined that the evidence presently before the Committee supports a determination that Mr. Collins violated House 

rules, laws, regulations, or other standards of conduct by failing to 

report outside income he had received from 2005 through 2010 on 

both his Financial Disclosure statements and his federal income 

taxes for each year. Mr. Collins has admitted that he did not report 

money he received between 2005 and 2009 as outside earned income. For his violation of House rules, laws, regulations, or other 

standards of conduct, Mr. Collins has agreed to accept a series of 

sanctions and remedies as discussed below. 

II. HOUSE RULES, LAWS, REGULATIONS, OR OTHER 

STANDARDS OF CONDUCT 

House Rule 26, clause 2 

‘‘[T]he provisions of title I of the Ethics in Government Act of 

1978 shall be considered Rules of the House as they pertain to 

Members, Delegates, the Resident Commissioner, officers, and employees of the House.’’ 

Ethics in Government Act 

‘‘Any individual who is an officer or employee described in subsection (f) during any calendar year and performs the duties of his 

position or office for a period in excess of sixty days in that calendar year shall file on or before May 15 of the succeeding year a 

report containing the information described in section 102(a).’’ 4

‘‘Each report filed pursuant to section 101 (d) and (e) shall include a full and complete statement with respect to . . . [t]he 

source, type, and amount or value of income (other than income referred to in subparagraph (B)) from any source (other than from 

current employment by the United States Government). . . .’’ 5

‘‘The head of each agency . . . each congressional ethics committee, or the Judicial Conference, as the case may be, shall refer 

to the Attorney General the name of any individual which such official or committee has reasonable cause to believe has willfully 

failed to file a report or has willfully falsified or willfully failed to 

file information required to be reported. . . .’’ 6

‘‘[A] Member or an officer or employee who is a noncareer officer 

or employee and who occupies a position . . . for which the rate of 

basic pay is equal to or greater than 120 percent of the minimum 

rate of basic pay payable for GS–15 of the General Schedule, may 

not in any calendar year have outside earned income attributable 

to such calendar year which exceeds 15 percent of the annual rate 

of basic pay for level II of the Executive Schedule under section 

5313 of title 5, United States Code, as of January 1 of such calendar year.’’ 7

‘‘[T]he outside earned income limit for Members and senior staff 

for calendar year 2009 is $26,550.’’ 8


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9 26 U.S.C. 7201. 

10See Appendix A at 1. 11 Id. 12 Id 13 Id 14 Id 

Internal Revenue Code 

‘‘Any person who willfully attempts in any manner to evade or 

defeat any tax imposed by this title or the payment thereof shall, 

in addition to other penalties provided by law, be guilty of a felony 

and, upon conviction thereof, shall be fined not more than $100,000 

($500,000 in the case of a corporation), or imprisoned not more 

than 5 years, or both, together with the costs of prosecution.’’ 9

House Rule 25, clause 1(a)(1) 

‘‘Except as provided by paragraph (b), a Member, Delegate, Resident Commissioner, officer, or employee of the House may not— 

(1) have outside earned income attributable to a calendar 

year that exceeds 15 percent of the annual rate of basic 

pay for level II of the Executive Schedule under section 

5313 of title 5, United States Code, as of January 1 of that 

calendar year.’’ 

III. BACKGROUND 

OCE Allegations 

On May 18, 2011, the OCE referred to the Committee a matter 

involving Mr. Michael Collins, Chief of Staff to Representative 

John Lewis, for further review. In its referral, OCE determined 

that there was ‘‘substantial reason to believe that Mr. Collins violated House rules and federal law by exceeding the outside earned 

income limit and failing to report the income on his Financial Disclosure Statements and federal income tax returns.’’ 10 OCE further 

determined that Mr. Collins was subject to an outside earned income limit of $26,550.11 According to OCE’s Report and Findings, 

Mr. Collins did not report income earned from the campaign on his 

2007, 2008, or 2009 Financial Disclosure Statements.12 OCE further reported that Mr. Collins exceeded the outside earned income 

limit for 2009 because he received $27,000 from the campaign that 

year.13 Furthermore, Mr. Collins did not disclose the income he received in 2009 on his federal income tax return.14

Mr. Collins’ Employment History 

Mr. Collins has paid federal income taxes for the last 29 years 

of his life. Mr. Collins began his career with Representative Lewis 

as his floor assistant in 1999; less than a year later he was promoted to Chief of Staff. Mr. Collins has received training from the 

Committee directed at senior staff (including training on outside 

earned income limits and financial disclosures) every year since the 

Committee instituted such training. 

Payments from the Campaign to Mr. Collins 

Committee staff, pursuant to the authority granted to the Chairman and Ranking Member under Committee Rule 18(a), reviewed 

Federal Election Commission (FEC) records from the John Lewis 


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15 See Appendix A, Exhibit 3–5. 16OCE interviewed Mr. Collins on March 9, 2011. See Appendix A at Exhibit 2. 17 Committee staff interviewed Mr. Collins on July 28, 2011. 18Mr. Collins, in his interview with Committee staff, was unable to recall when he began receiving consulting fees, as opposed to reimbursements. When Committee staff explained that 

they were unable to find records of income prior to 2005, Mr. Collins stated that it was likely 

he began receiving income in that year. 

for Congress campaign from 2000 through 2010. The campaign 

began paying a ‘‘consulting fee’’ for either fundraising or political 

strategy to Mr. Collins beginning in 2005 and continued to make 

such payments each year from 2005 through 2010 as indicated in 

Chart 1, below. 

CHART 1—INCOME PAYMENTS FROM CAMPAIGN TO MR. COLLINS 

Payment date Amount Description 

3/2/2005 ......................................... $5,000 .00 Fundraising Consulting Fee 

11/6/2006 ....................................... 7,000 .00 Fundraising Consulting Fee 

12/18/2007 ..................................... 5,000 .00 Consulting Fee/Political Strategy 

12/11/2008 ..................................... 10,000 .00 Campaign Management Consulting Fee 

8/19/2009 ....................................... 12,000 .00 Fundraising Consulting Fee 

12/14/2009 ..................................... 15,000 .00 Fundraising Consulting Fee 

According to these same FEC records, the John Lewis for Congress campaign paid Mr. Collins for certain expenses and reimbursed him for outlays he made to the campaign with his own 

funds. Some of these outlays also appear to violate campaign finance laws and House rules. Chart 2, below, lists the expense and 

reimbursement payments Mr. Collins received from the campaign 

according to FEC records.15

CHART 2—POSSIBLE REIMBURSEMENT PAYMENTS FROM CAMPAIGN TO MR. COLLINS 

Payment Date Amount Description 

1/31/2007 ....................................... $1,071 .76 Fundraising event expenses 

5/23/2007 ....................................... 892 .32 Volunteers appreciation event 

7/13/2007 ....................................... 1,595 .68 Expenses 

9/20/2007 ....................................... 973 .06 Expenses 

11/21/2007 ..................................... 475 .29 Expenses 

2/7/2008 ......................................... 499 .36 Expenses 

2/25/2008 ....................................... 475 .00 Reimbursement 

1/29/2009 ....................................... 1,148 .72 Reimbursement of credit card charges 

2/1/2009 ......................................... 7,000 .00 Reimbursement for storage unit rent 

Mr. Collins, in interviews with OCE16 and with Committee 

staff,17 admitted that he had received payments in the form of a 

consulting fee from the campaign. Mr. Collins, in his interview 

with the Committee, stated that he was never employed by the 

campaign as an employee, but performed work on his own time for 

the campaign and was compensated as an ‘‘agent.’’ He explained 

that he viewed this payment as a ‘‘bonus,’’ and noted that he was 

unable to receive a bonus directly from Representative Lewis’ office 

due to his salary level. He also admitted that he had received reimbursements for expenses from the campaign.18

Mr. Collins’ Financial Disclosure Statements 

OCE reviewed Mr. Collins’ Financial Disclosure Statements from 

2007 through 2009. OCE found that, in each year, Mr. Collins did 

not report any outside earned income, despite the payments from 


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19See Appendix A at 11–13. 20See Appendix A, Exhibit 2 at ¶17. 21See Appendix A at ¶53. 22See Appendix A, Exhibit 12. 23See Appendix A, Exhibit 7. 24See Appendix A, Exhibit 2 at ¶¶ 20, 48, and 54. 

the John Lewis for Congress campaign as listed in Chart 1, 

supra.19

Committee counsel also reviewed Mr. Collins’ Financial Disclosure Statements; because the Committee is not subject to OCE’s 

limitations period, Committee counsel’s review comprised those reports filed between 2000 and 2010. Committee counsel’s review 

confirmed OCE’s findings for the reports filed from 2007 through 

2009, and also discovered that Mr. Collins did not report any outside earned income from 2000 through 2007, despite the payments 

from the John Lewis for Congress campaign as listed in Chart 1, 

supra. In total, Mr. Collins failed to report $54,000 in income from 

2005 to 2009. Mr. Collins, after his interview with OCE, filed an 

amended Financial Disclosure Statement reporting the $27,000 he 

received from the campaign in 2009. 

Mr. Collins stated in his interview with OCE that his failure to 

disclose the income received from the John Lewis for Congress 

campaign on his Financial Disclosure Statements was due to ‘‘negligence.’’ 20 Similarly, in Mr. Collins’ interview with the Committee, 

he indicated that because the John Lewis for Congress campaign 

never sent him a Form W–2 or 1099 to document his payments, he 

never thought about the payments in terms of income, and so never 

reported them. Mr. Collins stated that he now 

*understands the need to list all outside earned income on his Financial Disclosure Statements, and stated his intention and willingness to amend all affected forms. 

Mr. Collins’ income tax returns 

OCE reviewed Mr. Collins’ Form 1040 federal income tax return 

for calendar year 2009. OCE determined that Mr. Collins had not 

reported the income he received from the campaign on his Form 

1040.21 Committee counsel reviewed Mr. Collins’ 2009 Form 1040 

and confirmed the finding of OCE that the $27,000 received from 

the campaign was not reported on his tax return.22 In the course 

of its investigation, OCE obtained a 1099–MISC form indicating 

that Mr. Collins received $27,000 in nonemployee compensation 

from John Lewis for Congress.23 Mr. Collins, after his interview 

with OCE, filed an amended tax return reporting the $27,000 he 

received from the campaign in 2009. Mr. Collins admitted in his 

interview with OCE that he did not report the $27,000 he received 

in 2009 on his federal income taxes and explained his failure to report was because he believed it was ‘‘not reportable income.’’ 24

When asked by Committee counsel to explain his failure to report the consulting fees that the campaign paid him on his tax return, Mr. Collins stated that because the John Lewis for Congress 

campaign never sent him a Form W–2 or 1099 to document the 

payments he received, he never thought about the payments in 

terms of income, and so never reported them. Mr. Collins acknowledged that if he had received this money as a ‘‘bonus’’ paid as a 

part of his House employment, it would have appeared on his Form 

W–2 and would consequently have been taxed. Mr. Collins stated 


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25See Appendix A at 15. 26 Id. at 16. 

that he now understands the need to list all income on his tax returns, and stated his intention and willingness to amend any and 

all affected tax returns. 

Exceeding the outside earned income limit 

Mr. Collins received $27,000 from the John Lewis for Congress 

campaign in 2009. In that year, the outside earned income limit for 

senior staff was $26,550.25 Because of his House rate of pay, Mr. 

Collins was considered senior staff for the purpose of the outside 

earned income limit.26

IV. FINDINGS AND CONCLUSIONS 

As a result of its review of OCE’s Report and Findings, and additional investigative activity by the Committee, the Committee has 

reached the following findings and conclusions. 

1. Michael Collins received $5,000 income from the John Lewis 

for Congress campaign in 2005 and failed to disclose that amount 

of outside income or its source on his Financial Disclosure Statement for 2005 or his federal income tax return for 2005, and failed 

to pay income taxes thereon. 

2. Michael Collins received $7,000 income from the John Lewis 

for Congress campaign in 2006 and failed to disclose that amount 

of outside income or its source on his Financial Disclosure Statement for 2006 or his federal income tax return for 2006, and failed 

to pay income taxes thereon. 

3. Michael Collins received $5,000 income from the John Lewis 

for Congress campaign in 2007 and failed to disclose that amount 

of outside income or its source on his Financial Disclosure Statement for 2007 or his federal income tax return for 2007, and failed 

to pay income taxes thereon. 

4. Michael Collins received $10,000 income from the John Lewis 

for Congress campaign in 2008 and failed to disclose that amount 

of outside income or its source on his Financial Disclosure Statement for 2008 or his federal income tax return for 2008, and failed 

to pay income taxes thereon. 

5. Michael Collins received $27,000 income from the John Lewis 

for Congress campaign in 2009 and failed to disclose that amount 

of outside income or its source on his Financial Disclosure Statement for 2009 or his federal income tax return for 2009, and failed 

to pay income taxes thereon. 

For his violation of House rules, laws, regulations, or other 

standards of conduct, in satisfaction of the sanctions and remedies 

unanimously adopted by the Committee, Mr. Collins has agreed to: 

(1) Waive all further procedural steps and rights he may be 

entitled to in this matter under House and Committee rules; 

(2) Accept a letter of reproval; 

(3) Amend his Financial Disclosure Statements for the years 

2005 through 2008 to correct all errors or omissions; 

(4) Pay a $1,000 fine (equivalent to five years of late Financial Disclosure filing fines) by December 31, 2011; 

(5) Provide to the Committee by September 30, 2011, an affidavit confirming that he has personally reviewed his income 


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27 House Rule XI, clauses 3(a)(2) and 3(b). 

tax returns and Financial Disclosure Statements for the last 

six years for any and all errors or omissions and that he has 

made all necessary corrections and amendments; 

(6) Amend his income tax returns for the years 2005 

through 2010 to correct all errors or omissions by September 

30, 2011; 

(7) Report to the Committee immediately upon a determination of what additional taxes or penalties he owes; 

(8) Pay all unpaid taxes, penalties, and interest owed for the 

years 2005 through 2010, either to the IRS or the U.S. Treasury, regardless of any statute of limitations, by a date to be set 

by the IRS or the Committee after it receives the report required under paragraph 7; 

(9) Verify with the Federal Election Commission that the $450 he returned to the campaign at the direction of OCE is 

a permissible payment. If not, the Campaign will need to return the $450 to Mr. Collins to avoid an impermissible contribution, and Mr. Collins will need to contribute $450 to a 

charitable organization properly registered and qualified under 

section 501(c)(3) of the Internal Revenue Code, by September 

30, 2011, so that Mr. Collins does not retain the excessive outside earned income; and 

(10) Provide the Committee with evidence of all of the above 

steps by the date indicated or to be set by the IRS or the Committee where applicable. 

Mr. Collins understands that failing to meet any of the above 

conditions at any time in this or future Congresses could result in 

further Committee action. Based on his admission and acceptance 

of responsibility for his actions, and his agreement to the above 

sanctions and remedies, the Committee has determined that this 

matter is closed, subject to Mr. Collins fulfilling the above conditions. 

The Chair is directed, upon providing the notices required pursuant to House Rule XI, clause 3(b)(8)(A), and Committee Rule 

17A(a)(2), to file this Report with the House, together with a copy 

of OCE’s Report and Findings in this matter, along with any responses filed, all of which are made a part of this Report and appended hereto.27 The filing of this Report, along with its publication on the Committee’s Web site, shall serve as publication of 

OCE’s Report and Findings in this matter, pursuant to House Rule 

XI, clause 3(b)(8)(A), and Committee Rules 17A(b)(3) and 17A(c)(2). 

V. STATEMENT UNDER RULE 13, CLAUSE 3(c) OF THE 

RULES OF THE HOUSE OF REPRESENTATIVES 

The Committee made no special oversight findings in this Report. 

No budget statement is submitted. No funding is authorized by any 

measure in this Report. 


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erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 84 here HR193.072
80 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 85 here HR193.073
81 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 86 here HR193.074
82 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 87 here HR193.075
83 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 88 here HR193.076
84 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 89 here HR193.077
85 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 90 here HR193.078
86 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 91 here HR193.079
87 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 92 here HR193.080
88 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 93 here HR193.081
89 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 94 here HR193.082
90 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 95 here HR193.083
91 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 96 here HR193.084
92 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 97 here HR193.085
93 

Æ 


erowe on DSK2VPTVN1PROD with REPORTSInsert graphic folio 98 here HR193.086