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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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Last modified: May 25, 2011