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A deputy director for the Department of Agriculture requested a decision regarding the right of Government employees to items won from coupons or other material distributed by air carriers, when receipt of such materials is not contingent upon the travel which is being performed. In requesting a decision, the director referred to a bulletin which stated in part that any and all material received by personnel while on official travel becomes the property of the U.S. Government. At the time the bulletin was issued, it was mainly directed toward the recovery of half-fare coupons received by employees incident to the purchase of airline tickets for official travel. However, since that time, air carriers have also sponsored a variety of promotional campaigns open to the general public in which prizes may be won without having to purchase tickets. The director felt that a distinction should be made between promotional material distributed in those circumstances, and the half-fare coupons or similar items of value distributed only to ticket-holding passengers. GAO reviewed the regulations and concluded that, if an employee traveling on official business enters a contest sponsored by an air carrier which is open to the general public and not just to ticket-holding passengers, then the transaction may be regarded as the employee's own personal affair; he would not have a duty to account for any prizes won. However, this conclusion does not alter the fundamental rule requiring a Federal employee to account for any benefit received from private sources incident to the performance of official duty.

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