Steven J. and Terry L. Namyst - Page 12

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               In order to meet the substantiation requirement of section             
          1.62-2(e), Income Tax Regs., petitioner must have actually                  
          submitted his substantiation to IMC in order to be reimbursed.              
          We have found above that petitioner submitted expense reports to            
          Mr. Kerkinni annually, and he showed Mr. Kerkinni the receipts              
          after each expenditure was made.  Petitioner’s records were kept            
          carefully, and at the end of each year, he submitted an accurate            
          list of his expenditures.  That petitioner kept Mr. Kerkinni                
          informed of his expenditures when they were made helps to                   
          convince us that it was reasonable for petitioner to submit a               
          detailed list only annually.                                                
               C.   Returning Amounts in Excess of Expenses                           
               Section 1.62-2(f), Income Tax Regs., provides that an                  
          arrangement meets the third requirement of an accountable plan if           
          the employee is required to return to the payor within a                    
          reasonable period of time any amount paid under the arrangement             
          in excess of the expenses substantiated.  When an employer                  
          advances money to an employee for anticipated expenses, paragraph           
          (f) of section 1.62-2, Income Tax Regs., is satisfied only if the           
          amount of money advanced is reasonably calculated not to exceed             
          the amount of anticipated expenditures, the advance is made                 
          within a reasonable period of when the expenditures are made, and           
          any excess of the advance over the substantiated expenses is                
          required to be repaid within a reasonable period after the                  






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