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On Schedule A, petitioner reported unreimbursed employee
expenses of $26,188.74. Petitioner itemized the expenses on Form
2106 as follows: $19,779.66 of travel expenses, $5,161.32 of
business expenses, and $1,247.761 of meals and entertainment
expenses. Subject to the 2 percent of adjusted gross income
limitation, petitioner claimed total unreimbursed employee
business expense deductions of $24,408.44. He did not report any
reimbursements received from the college.
The parties agree that petitioner spent a total of $3,404.51
on hotels during 2002 and claimed this amount as part of the
travel expenses listed on Form 2106 for 2001. The parties also
agree that petitioner spent $2,606.61 on other expenses and
included this amount as part of the other business expenses
claimed on his Form 2106.
B. The College’s Reimbursement Policies
As relevant herein, the college had two reimbursement
policies in effect during 2001. Under Procedure 3280,
Reimbursement to College Employees for College-Related Purchases
Not Exceeding $200 (small purchase reimbursement policy),
petitioner was required to obtain advance supervisory approval
for purchases of college-related materials and services not
1The $1,247.76 petitioner reported for meals and
entertainment expenses is one-half of the total amount petitioner
spent for meals and entertainment expenses during 2001.
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