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Pacific Bell to the position of premise sales manager of outside
and inside sales representatives. As premise sales manager,
petitioner was responsible for achieving sales commitments for a
specific territory through the supervision, motivation, and
development of sales representatives; designing and implementing
sales campaign strategies; handling customer contacts; reviewing
the accuracy of paperwork; and preparing administrative reports.
Petitioner's territory included the coastal region from Malibu to
Palos Verdes, plus Alhambra, Pasadena, and Orange County.
Petitioner had an office at Pacific Bell that was located in
downtown Los Angeles (the downtown office). Petitioner's
schedule varied daily, and she had no set routine. Sometimes she
worked at her home in the morning and drove to the downtown
office or a satellite office in the afternoon. On other
occasions, she worked at the downtown office all day or visited
customers during the day. In 1991, petitioner paid for a parking
space near the downtown office. Petitioner believed it was a
necessity to have her car at the downtown office in case she
needed to visit a customer, satellite office, or perform other
business-related activities.
According to a stipulated letter from Cheryl Groves, who is
a premise sales manager at Pacific Bell, company business
expenses for "parking charges" were reimbursable by Pacific Bell.
It is not clear from this letter whether such charges refer only
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Last modified: May 25, 2011