Rev. Rul. 84-51

1984-1 C.B. 90, 1984-15 I.R.B. 4.

                       Internal Revenue Service
                                 Revenue Ruling

              TRAVEL EXPENSES;  REIMBURSEMENT;  MILEAGE ALLOWANCES

                            Published: April 9, 1984

Section 61. - -Gross Income Defined, 26 CFR 1.61-6:  Gains derived from dealings in property.

Section 162. - -Trade or Business Expenses, 26 CFR 1.162-17: Reporting and substantiation of certain business expenses of employees.

Section 274. - -Disallowance of Certain Entertainment, Etc., Expenses, 26 CFR 1.274-5:  Substantiation requirements.

(Also Section 162;  1.162-17.)

  Travel expenses;  reimbursement;  mileage allowances.  With respect to expenses paid or incurred after 1982, mileage allowances not exceeding 20.5 cents per mile for transportation paid by employers to employees will satisfy the substantiation and adequate accounting requirements of sections 1.162-17(b) and 1.274-5 of the regulations.  Rev. Rul. 80-62, as modified by Rev. Rul. 80- 203, is further modified.

  This revenue ruling modifies Rev. Rul. 80-62, 1980-1 C.B. 63, as modified by Rev. Rul. 80-203, 1980-2 C.B. 101, with respect to the mileage allowance for transportation paid by employers to employees.

  The sixth paragraph of Rev. Rul. 80-62, which paragraph was modified by Rev. Rul. 80-203, is further modified as follows:

  If a fixed mileage allowance not exceeding 20.5 cents per mile is used by an employer in payment of an employee's ordinary and necessary expenses of transportation while traveling away from home, and the elements of time, place, and business purpose of the travel are substantiated in accordance with paragraphs (b)(2) and (c) (other than subparagraph (2)(iii)(a) thereof) of section 1.274-5 of the regulations, such an allowance shall be deemed as satisfying with respect to such travel amounts, the substantiation requirements of section 1.274-5(c) and the adequate accounting requirements of section 1.274-5(e).  Also, if an employer grants an allowance not exceeding 20.5 cents per mile to an employee for ordinary and necessary transportation expenses not involving travel away from home, such an arrangement shall be considered to be an accounting to the employer within the meaning of section 1.162-17(b). However, an employer may grant an additional allowance for parking fees and tolls attributable to the traveling and transportation expenses as separate items.

  This modification is effective with respect to expenses paid or incurred after December 31, 1982.

EFFECT ON OTHER REVENUE RULINGS

  Rev. Rul. 80-62, as modified by Rev. Rul. 80-203, is further modified.

Rev. Rul. 84-51, 1984-1 C.B. 90, 1984-15 I.R.B. 4.