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such expenses, they were reimbursable.
During January 1 through May 22, 2001, pursuant to the FedEx
policies, petitioner received reimbursements from FedEx Express
for certain allowable reasonable expenses that he paid.5 During
June 21 through December 7, 2001, pursuant to the FedEx policies,
petitioner received reimbursements from FedEx Worldwide Services
for certain allowable reasonable expenses that he paid.
During certain unidentified travel freezes in 2001, peti-
tioner paid certain unidentified expenses as a FedEx Worldwide
Services employee for which he did not submit any requests for
reimbursement and for which he made no attempt to obtain the
approval of a vice president authorizing reimbursement of such
expenses.
In addition to working full time during the year at issue
for FedEx Worldwide Services, on April 4, 2001, petitioner sent
an e-mail addressed to Donna Dubinsky (Ms. Dubinsky), the chief
executive officer of Handspring, a manufacturer of a device known
as a personal digital assistant (Handspring’s PDA). In that e-
mail, petitioner renewed the offer that he had made in two e-
mails addressed to Ms. Dubinsky that he had sent on November 20,
5The record does not disclose why FedEx Express, rather than
petitioner’s employer FedEx Worldwide Services, reimbursed
petitioner for certain allowable reasonable expenses that he paid
during the year at issue. We presume that FedEx Worldwide
Services permitted petitioner to work on a project for FedEx
Express during that year and that FedEx Express reimbursed him
for the allowable reasonable expenses relating to that project
that he paid.
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