(Editor’s Note.  The Federal Travel Regulation generally permits employees to make personal choices about their type of transportation while on official travel yet the following makes clear the limits of reimbursement can be the cheapest possible cost if there is a range of amounts.)

Rather than take a taxi, Mr. Pruett drove from his house and parked his car at the airport and when he returned, he retrieved his car and drove to his office.  His request for reimbursement was $92 – $12 for mileage and $80 for parking fees.  Pruett asserted this amount was virtually equal to the cost paid for a taxi, explaining he had previously paid between $42 and $45 for trips to the airport and $35 for a trip to the office.  The agency reimbursed him only $65, indicating the “constructive” taxi fare should be $77 - $42 and $35 for the two trips and no expense for the mileage expense.  The appeals board agreed with the agency about the constructive taxi fare limit asserting (1) FTR 301-70.100 requires agencies to limit payment of transportation expenses to those costs that result in the “greatest advantage to the government” (i.e. cheapest) (2) FTR 301-10.420(b)(I) provides that employees may be reimbursed the “usual fare” for taxis between home and airport and (3) FAR 301010.402 permits employees to drive to the airport rather than take a taxi and be reimbursed that expense plus parking fees as long as the limit of reimbursement is the “constructive cost of a taxi.”  The Board ruled the agencies calculation of the taxi’s constructive cost was reasonable because they can properly compute the lowest possible base when there is a range of possible charges.  Despite the correctness of the agency’s constructive cost calculation, the Board ruled it was improper to deduct Pruett’s claimed mileage expense because such a deduction was not supported by the FTR (GSBCA 16409-TRAV).

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