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with that policy, IHS paid petitioner $1,800 in automobile
allowances during 1993. IHS also had a company policy of
reimbursing its sales personnel for all ordinary and necessary
business expenses upon submission of periodic expense reports.
During the first quarter of 1993, petitioner prepared and
submitted to IHS periodic expense reports for expenses incurred
in 1993. IHS reimbursed him $2,129 for his 1993 employee
business expenses in addition to the automobile allowance.
Starting in April 1993, petitioner was employed as a
salesman for the Human Resource Information Group (HRIG), a
division of ETSI, Inc., of Gaithersburg, Maryland. HRIG had a
company policy of reimbursing all ordinary and necessary business
expenses incurred by its employees. During 1993, petitioner
prepared and submitted to HRIG periodic expense reports for
expenses incurred in 1993. HRIG reimbursed him $23,044 for his
1993 employee business expenses.
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