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decision is whether petitioner is entitled to deduct unreimbursed
employee expenses and miscellaneous expenses claimed on Schedule
A in the amount of $12,694.
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition, petitioner resided in Manhattan Beach, California.
During the 1993 taxable year, petitioner was employed by
Texas Instruments (TI) as an outside field sales representative.
Petitioner was employed by TI from July 14, 1986, until January
4, 1994. As an outside field sales representative, petitioner’s
duties consisted of calling on the engineering and purchasing
groups of certain technical companies (hereinafter referred to as
customers). Petitioner was successful at his job by increasing
his sales every year and was voted “most valuable player” for the
years 1992 and 1993. Petitioner earned $86,176.56 in
compensation from TI in 1993.
Petitioner met regularly with customers to discuss business,
and frequently they would meet at restaurants. If petitioner
paid the restaurant bill, he would occasionally seek
reimbursement from TI. When seeking reimbursement from TI,
petitioner would fill out a form stating the date, time, amount
spent, nature of business, individuals present and with which
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