B-164357, JUL. 1, 1968

B-164357: Jul 1, 1968

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IS BROKEN DOWN INTO MATERIALS AND LABOR FOR HOOKING UP MOBILE HOME. YOU HAVE PAID MR. HIS WEEKLY SALARY RATE IS $224 AND YOU INQUIRE AS TO WHETHER ANY OF THE EXPENSES DISALLOWED COULD NOT HAVE BEEN CONSIDERED AS MISCELLANEOUS EXPENSES IN ORDER TO INCREASE THE AMOUNT ALLOWABLE TO THE EXTENT OF MR. NOR CHARGES DESIGNATED IN THE TARIFFS AS -SPECIAL SERVICE.- " THE COSTS OF UNBLOCKING THE TRAILER AND TAKING DOWN THE AWNING ARE EXPENSES OF PREPARATION AND ARE. SINCE THESE ITEMS ARE FOR NECESSARY EXPENSES INCIDENT TO RELOCATION OF THE TRAILER WE SEE NO REASON WHY THEY MAY NOT BE CONSIDERED AS MISCELLANEOUS EXPENSES UNDER SECTION 3.1 OF THE REGULATIONS. WITH RESPECT TO THE OTHER THREE ITEMS THE ONE FOR $46.80 FOR INSTALLING AN AWNING IS NOT AN EXPENSE THAT IS COMMON TO LIVING QUARTER FURNISHINGS.

B-164357, JUL. 1, 1968

TO CAPTAIN J. E. DUNKLEY:

THIS REFERS TO YOUR LETTER OF APRIL 30, 1968, REFERENCE DCRA-FOAAP, REQUESTING AN ADVANCE DECISION OF OUR OFFICE ON THE RECLAIM VOUCHER OF MR. CHARLES E. TREPPARD, AN EMPLOYEE OF THE DEFENSE SUPPLY AGENCY, FOR EXPENSES IN CONNECTION WITH MOVING HIS TRAILER (MOBILE HOME) PURSUANT TO A CHANGE OF OFFICIAL STATION FROM NASHVILLE TO MEMPHIS,TENNESSEE.

MR. TREPPARD ORIGINALLY CLAIMED $374.41 FOR EXPENSES OF MOVING AND HOOKING UP HIS TRAILER. OF THAT AMOUNT, $115.22 REPRESENTS EXPENSES OF $95.22 FOR ACTUALLY TRANSPORTING THE TRAILER PLUS $7.50 FOR UNBLOCKING IT AND $12.50 FOR TAKING DOWN AN AWNING. YOU ALLOWED THE ITEM FOR $95.22 AND DISALLOWED THE OTHER TWO ITEMS. THE REMAINING AMOUNT OF $259.19, ALSO DISALLOWED BY YOU, IS BROKEN DOWN INTO MATERIALS AND LABOR FOR HOOKING UP MOBILE HOME, $52.39, FURNISHING AND INSTALLING PROPER ELECTRIC WORK FOR THE MOBILE HOME, $160, AND INSTALLING AWNING, $46.80.

YOU HAVE PAID MR. TREPPARD THE SPECIFIED ALLOWANCE OF $100 FOR MISCELLANEOUS EXPENSES AS A SINGLE MAN. HIS WEEKLY SALARY RATE IS $224 AND YOU INQUIRE AS TO WHETHER ANY OF THE EXPENSES DISALLOWED COULD NOT HAVE BEEN CONSIDERED AS MISCELLANEOUS EXPENSES IN ORDER TO INCREASE THE AMOUNT ALLOWABLE TO THE EXTENT OF MR. TREPPARD'S WEEKLY SALARY.

WITH RESPECT TO THE COMPUTATION OF ALLOWANCES FOR TRANSPORTING A TRAILER BY COMMERCIAL MEANS, SECTION 9.3A OF BUREAU OF THE BUDGET CIRCULAR NO. A- 56 PROVIDES AS FOLLOWS:

"/1) THE ALLOWANCE SHALL INCLUDE THE CARRIER'S CHARGES FOR ACTUAL TRANSPORTATION OF THE TRAILER IN AN AMOUNT NOT EXCEEDING THE APPLICABLE TARIFF AS APPROVED BY THE INTERSTATE COMMERCE COMMISSION (OR APPROPRIATE STATE REGULATORY BODY FOR INTRASTATE MOVEMENTS) FOR TRANSPORTATION OF A TRAILER OF THE SIZE AND TYPE INVOLVED FOR THE DISTANCE INVOLVED, COMPUTED AS PROVIDED IN SECTION 9.2.

"/3) ALLOWANCES SHALL NOT INCLUDE COSTS OF PREPARING TRAILERS FOR MOVEMENT, MAINTENANCE, REPAIRS, STORAGE, INSURANCE FOR VALUATION OF TRAILERS ABOVE CARRIERS' MAXIMUM RESPONSIBILITY, NOR CHARGES DESIGNATED IN THE TARIFFS AS -SPECIAL SERVICE.- "

THE COSTS OF UNBLOCKING THE TRAILER AND TAKING DOWN THE AWNING ARE EXPENSES OF PREPARATION AND ARE, THEREFORE, NOT ALLOWABLE UNDER SECTION 9.3A (3) OF THE REGULATIONS ABOVE. BUT SINCE THESE ITEMS ARE FOR NECESSARY EXPENSES INCIDENT TO RELOCATION OF THE TRAILER WE SEE NO REASON WHY THEY MAY NOT BE CONSIDERED AS MISCELLANEOUS EXPENSES UNDER SECTION 3.1 OF THE REGULATIONS.

WITH RESPECT TO THE OTHER THREE ITEMS THE ONE FOR $46.80 FOR INSTALLING AN AWNING IS NOT AN EXPENSE THAT IS COMMON TO LIVING QUARTER FURNISHINGS, HOUSEHOLD APPLIANCES AND OTHER GENERAL TYPES OF COSTS INHERENT IN THE RELOCATION OF A PLACE OF RESIDENCE WITHIN THE MEANING OF SECTION 3.1B OF THE BUREAU'S REGULATIONS. IT IS MORE IN THE NATURE OF A STRUCTURAL ALTERATION FOR WHICH REIMBURSEMENT IS NOT AUTHORIZED. SEE SECTION 3.1C (12) OF BUREAU OF THE BUDGET CIRCULAR NO. A-56, ALSO B-161562, NOVEMBER 2, 1967 (COPY ENCLOSED). YOU WILL NOTE THAT WE HAVE ASSUMED THAT THIS ITEM COVERS THE INSTALLATION OF A NEW AWNING RATHER THAN THE AWNING TAKEN DOWN AT THE OLD STATION.

WHILE THE ITEM OF $52.39 FOR HOOKING UP THE MOBILE HOME IS SUFFICIENTLY RELATED TO CONNECTING UTILITIES TO SHOW SOME EXPENSE OF ESTABLISHING A RESIDENCE AND THEREBY FOR INCLUSION UNDER THE ALLOWANCE FOR MISCELLANEOUS EXPENSES, NEVERTHELESS, THE COSTS AND NATURE OF THE WORK AND MATERIALS ARE NOT SUFFICIENTLY IDENTIFIED TO ENABLE A DETERMINATION TO BE MADE WITH RESPECT THERETO. IN OTHER WORDS IF THIS ITEM IS FOR WATER LINE AND SEWAGE WORK IT MAY INCLUDE INSTALLATION OF ADDITIONAL PIPES WHICH WOULD NOT BE ALLOWABLE. LIKEWISE, THE ITEM OF $160 FOR ELECTRIC WORK IN MR. TREPPARD'S MOBILE HOME IS NOT SUFFICIENTLY DETAILED TO ENABLE A DETERMINATION AS TO WHAT PART THEREOF MAY BE INCLUDED AS MISCELLANEOUS EXPENSES. FROM THE DESCRIPTION OF THE WORK IT MAY HAVE INVOLVED INSTALLATION OF NEW EQUIPMENT OR NEW CIRCUITS WHICH ARE NOT REIMBURSABLE AS MISCELLANEOUS EXPENSES. SEE SECTION 3.1C (12), BUREAU OF THE BUDGET CIRCULAR NO. A 56 AND B-163449, MARCH 4, 1968 (COPY ENCLOSED).

ACCORDINGLY, ON THE BASIS OF THE PRESENT RECORD THERE IS NO GROUND FOR REIMBURSING MR. TREPPARD FOR MISCELLANEOUS EXPENSES IN EXCESS OF $100. THE VOUCHER AND SUPPORTING PAPERS ARE RETURNED HEREWITH.