Steve D. Putnam - Page 6

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               At trial, respondent called as a witness Gloria Nero (Ms.              
          Nero), who is the asset accounting manager for TI.  Ms. Nero                
          supervises employees whose responsibility it is to audit expense            
          statements of TI employees to see whether they conform to TI                
          policy.  If they conform, they are submitted for payment, and the           
          employee who incurred the expense will be reimbursed.  Ms. Nero             
          presented a copy of the reimbursement policy that was in effect             
          for 1993.                                                                   
               According to Ms. Nero and the reimbursement policy,                    
          employees are reimbursed by TI for meals and entertainment,                 
          travel, business gifts, alcohol purchases, and computer services.           
          It does not matter what time of day or which day of the week meal           
          expenses are incurred, so long as they are for a TI business                
          purpose and are ordinary and necessary.                                     
               Respondent contends that the expenses petitioner incurred              
          should not be allowed as unreimbursed business expenses, because            
          TI would have reimbursed petitioner if he had submitted an                  
          expense report.  Respondent also contends that if the expenses              
          were not allowed by TI, it is because the expenses are primarily            

          5(...continued)                                                             
          deductions that were disallowed.  Rule 142(a).  Petitioner                  
          offered no testimony and introduced no evidence regarding the               
          other claimed deductions.  We therefore find that petitioner                
          abandoned the remaining items, and those deductions will not be             
          allowed.  Items that were not discussed include:  Telephone,                
          business clothing and cleaning, dues, business expenses, cellular           
          phone, tax preparation, office supplies and postage, investment             
          income expense, and miscellaneous.                                          




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