B-140073, SEPTEMBER 4, 1959, 39 COMP. GEN. 164

B-140073, SEPTEMBER 4, 1959, 39 COMP. GEN. 164

CIVILIAN PERSONNEL - TRAVEL EXPENSES - CREDIT CARDS - RECEIPTS CREDIT CARDS WHICH EVIDENCE EXPENSES INCURRED BY GOVERNMENT EMPLOYEES IN A TRAVEL STATUS FOR GOODS OR SERVICES--- SUCH AS AN INVOICE FOR THE HIRE OF AN AUTOMOBILE CHARGED TO THE EMPLOYEE'S DINERS' CLUB MEMBERSHIP--- WILL BE CONSIDERED IN THE NATURE OF A RECEIPT IN SATISFACTION OF THE RECEIPT REQUIREMENTS IN SECTION 11 OF THE STANDARDIZED GOVERNMENT TRAVEL REGULATIONS, EVEN THOUGH THE INVOICE DETAILING THE EXPENSES DOES NOT REFLECT CASH PAYMENT, PROVIDED THAT UNDER THE CREDIT ARRANGEMENT THE GOVERNMENT COULD NOT BE HELD LIABLE TO THE VENDOR OR TO THE DINERS' CLUB IN THE EVENT OF NONPAYMENT OF THE OBLIGATION BY THE EMPLOYEE-TRAVELER.

TO MATILDA UDOFF, DEPARTMENT OF COMMERCE, SEPTEMBER 4, 1959:

ON JUNE 30, YOUR FILE REFERENCE 40.04, YOU SUBMITTED FOR ADVANCE DECISION A RECLAIM VOUCHER FOR $103.87 IN FAVOR OF MR. THOMAS O. TWIST, AN EMPLOYEE OF THE BUREAU, COVERING THE AUTHORIZED HIRE OF AN AUTOMOBILE WHILE TRAVELING ON OFFICIAL BUSINESS.

MR. TWIST DID NOT FURNISH A RECEIPT SHOWING THAT HE HAD PAID THE COST, ALTHOUGH AN INVOICE OF THE HERTZ COMPANY SHOWING THE AMOUNT AND BASIS OF THE CHARGES AND STAMPED " DINERS' CLUB" WAS FURNISHED. YOU ASK WHETHER "BILLS CHARGED TO A TRAVELER'S DINERS' CLUB MEMBERSHIP ACCOUNT, OR OTHER SIMILAR ACCOUNTS, MAY BE CONSIDERED AS "A RECEIPTED BILL OR OTHER FORM OF RECEIPT" AS REQUIRED IN SECTION 11.1E OF THE STANDARDIZED GOVERNMENT TRAVEL REGULATIONS IN CONNECTION WITH THE HIRE OF SPECIAL CONVEYANCES, OR FOR ANY OTHER EXPENSES REQUIRING RECEIPTS.'

SECTION 11 OF THE REGULATIONS, SO FAR AS IS PERTINENT HERE, IS AS FOLLOWS:

11.1 RECEIPTS REQUIRED.--- RECEIPTS FOR ALLOWABLE CASH EXPENDITURES IN AMOUNTS IN EXCESS OF $15, PLUS ANY APPLICABLE TAX, WHEN PRACTICABLE TO OBTAIN THEM, WILL BE REQUIRED FOR:

(E) HIRE OF SPECIAL CONVEYANCE SUCH AS LIVERY, BOAT, AUTOMOBILE (NOT TAXICABS LOCALLY), AIRCRAFT, ETC. (SEE SEC. 3.4) LIVERY AND OTHER SPECIAL TRANSPORTATION RECEIPTS MUST DESCRIBE THE SERVICE HIRED, THE SERVICE RENDERED, AND THE RATE OF COMPENSATION BY THE DAY, HOUR, OR OTHER UNIT, AS MAY HAVE BEEN AGREED. IF THE SUBSISTENCE OF DRIVER OR TEAM IS INCLUDED IN THE COST, THAT FACT MUST BE STATED. A RECEIPTED BILL OR OTHER FORM OF RECEIPT WILL BE ACCEPTED, PROVIDED IT IS MADE OUT TO SHOW THE PERIOD AND SERVICE RENDERED, OR ARTICLES PURCHASED, AND THE UNIT PRICE.

THE TERM "RECEIPT" REFERS ORDINARILY TO A WRITTEN ACKNOWLEDGMENT TO THE TRAVELER THAT HE HAS PAID A CERTAIN SUM OF MONEY AS AN EXPENSE OF HIS TRAVEL. THE RECEIPT REQUIRED BY THE REGULATIONS, IN ADDITION TO ESTABLISHING THE FACT OF PAYMENT BY THE TRAVELER, SERVES AS EVIDENCE OF THE AMOUNT PAID AND--- OF PRIME IMPORTANCE--- DETAILS THE NATURE OF THE EXPENSE AND THE BASIS FOR THE CHARGES. WHEN THE TRAVELER OBTAINS GOODS OR SERVICES ON HIS PERSONAL CREDIT EITHER BY DIRECT ARRANGEMENT WITH THE VENDOR OR, AS HERE, THROUGH A DINERS' CLUB OR SIMILAR CREDIT CARD ACCOUNT, THE INVOICE FROM THE VENDOR DETAILING THE NATURE AND AMOUNT OF THE EXPENSES NATURALLY CANNOT REFLECT CASH PAYMENT AND, THEREFORE, SUCH AN INVOICE NORMALLY WOULD NOT QUALIFY AS A "RECEIPT" IN THE STRICT SENSE OF THE WORD.

HOWEVER, RECOGNIZING THAT CREDIT ARRANGEMENTS, PARTICULARLY THE CREDIT CARD ACCOUNTS AVAILABLE TO TRAVELERS, NOW CONSTITUTE A GENERALLY ACCEPTED METHOD OF DOING BUSINESS, WE WILL REGARD EVIDENCE OF A PERSONAL OBLIGATION INCURRED BY A TRAVELER FOR ALLOWABLE GOODS AND SERVICES, SUCH AS THE HERTZ COMPANY'S INVOICE HERE, AS BEING IN THE NATURE OF A "RECEIPT" AND AS SATISFYING THE REQUIREMENT OF SECTION 11 OF THE TRAVEL REGULATIONS.

IT MUST APPEAR ALSO, FROM THE NATURE OF THE TRANSACTION, AS IT DOES HERE, THAT THE GOVERNMENT COULD NOT BE HELD LIABLE TO THE VENDOR OR THE DINERS' CLUB IN THE EVENT OF NONPAYMENT OF THE OBLIGATION BY THE TRAVELER.

THEREFORE, THE VOUCHER WHICH, ALONG WITH SUPPORTING PAPERS, IS RETURNED HEREWITH MAY BE CERTIFIED FOR PAYMENT IF OTHERWISE CORRECT.