Cellular phones and email devices owned by the university are considered listed property by the IRS.  According to the IRS, listed property is defined as items obtained for use in a business but lending themselves easily to personal use.  Because the nature of the property lends itself to personal use, strict substantiation requirements are in place.  Employees are required to account for business and personal use.  If substantiation requirements are not met, all use is included in the wages of the employee as per IRC SECTION 274 (d); IRC SECTION 280F (d)(4); SECTION 132 (d).