Zabetti A. Pappas - Page 3

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          1990; (4) whether petitioner failed to report sales and rental              
          income she received during 1989 and 1990; (5) whether petitioner            
          may deduct business expenses in excess of those allowed by                  
          respondent for 1989 and 1990; (6) whether respondent properly               
          reconstructed petitioner’s 1991 and 1992 taxable income through             
          the use of Bureau of Labor Statistics data; (7) whether                     
          petitioner is liable for the additions to tax under section                 
          6651(f) or, in the alternative, for the additions to tax under              
          section 6651(a) for the years at issue; and (8) whether                     
          petitioner is liable for the additions to tax under section                 
          6654(a) for the years at issue.                                             
                                  FINDINGS OF FACT                                    
               Petitioner Zabetti A. Pappas was a resident of New York, New           
          York, at the time the petition herein was filed.  She did not               
          file Federal income tax returns for the taxable years at issue,             
          nor did she make estimated tax payments for those years.                    
          1.  Petitioner and Real Services, Inc.                                      
               Petitioner attended Vassar College from 1976 through                   
          approximately 1978.  Thereafter, she held a variety of jobs,                
          including operating a business known as “Disco Queen”.  She was             
          known to her associates and clientele in New York as “Z” or                 
          “Betty” or “Angel”.  Petitioner was actively involved in a number           
          of income-producing activities.  She operated a prostitution                
          business, in which she arranged for other women or herself to               

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