Gerard and Audrey Kathleen Hennessey - Page 6




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          expenses (for example, the cost of filing a patent application)             
          before any royalties were paid.                                             
               According to petitioner, she typically traveled on                     
          approximately 150 trips per year as part of her duties with the             
          University, ISOA Consulting, and ISOA, Inc.  She testified that             
          University professors could be reimbursed for employment-related            
          travel expenses only to the extent of $1,000 per year.2  Grants             
          obtained by petitioner on behalf of the University also provided            
          for some paid travel expenses.  According to petitioner, any                
          remaining travel expenses were paid by petitioners.                         
               The University’s policy required that petitioner provide an            
          expense report for each trip regardless of whether her travel               
          expenses were ultimately reimbursed.  According to petitioner:              
          (1) Original travel receipts were attached to the expense reports           
          submitted to the University; (2) a travel reimbursement check               
          from the University was usually received within 5 or 6 months               
          after submitting an expense report; and (3) the reimbursement               
          check did not always identify the specific travel expenses for              
          which petitioner was being reimbursed.  Petitioner did not keep             
          records of what travel was reimbursed by the University, nor did            




               2 This testimony appears to be inconsistent with the                   
          reimbursement evidence from the University, as well as the                  
          amounts reported by petitioners as reimbursements on their tax              
          returns and “general ledgers”.                                              






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