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because it increased his sales. Petitioner did not explain why
he was granted reimbursement from TI for at least eight evening
meals and seven weekend meals, which were presumably on his own
time. Petitioner also did not explain why he did not seek
reimbursement for the five weekday lunches he claimed deductions
for.
Petitioner went with customers on two ski weekends to Aspen,
Colorado, and Mammoth, California. Petitioner bought meals and
lift tickets for the customers. On these trips and at some of
the meals, petitioner’s fiancee, Jodi Knox (Ms. Knox), was
present.
Twice during 1993, petitioner and Ms. Knox attended the
weddings of customers. The customers were also petitioner’s
friends. One wedding was in British Columbia, and the other was
in Baltimore, Maryland. For both weddings, expenses were
incurred for airfare, hotels, rental cars, and meals. Petitioner
deducted these expenses as unreimbursed business expenses.
Petitioner also deducted $167 for professional publications.
Petitioner subscribes to newspapers, allegedly so he can be
apprised of new companies and check the financial well-being of
existing companies in his territory.
Petitioner purchased a modem and motherboard for his home
computer. This enabled him to log into the TI database from
home. Petitioner was told that TI did not reimburse computer
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Last modified: May 25, 2011