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business they are associated, name of restaurant, and purpose,
benefit, and nature of discussion. Petitioner mostly sought
reimbursement of business lunches and occasionally dinners. For
example, petitioner was reimbursed for 77 meals in 1993, and of
those, at least 8 were evening dinners and 7 took place on the
weekend.2
On his return, petitioner deducted amounts for meals that
were not reimbursed by TI. According to petitioner, his boss at
the time, Robert Fullerton (Mr. Fullerton), told petitioner that
TI would not reimburse for dinners, alcohol, or any weekend
expenditures, even though they were incurred with customers.
According to petitioner, Mr. Fullerton’s reasoning was that time
after work and on the weekend was considered the employee’s own
time.
Petitioner took customers out for numerous meals during his
own time. Petitioner presented copies of restaurant receipts
that he retained.3 Of roughly 46 receipts, most of the meals
were evening dinners, while about 5 were for weekday meals during
the day. Petitioner incurred expenses during his own time
2 This information was obtained from copies of credit card
receipts that petitioner turned in to TI for reimbursement. The
time of day is printed on certain receipts. We note that on 39
of the 77 receipts, the time of day was either not printed or was
illegible.
3 The copies were, in some instances, too difficult to
decipher.
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