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During the years in issue, petitioner’s principal residence
was an apartment at 500 E. 77th Street in New York. She took
over the lease of that apartment in the early 1980s from an
individual named Joy C. but continued to use Ms. C.’s name on
documents regarding that lease. She did not use her own name or
that of Real Services. Petitioner shared the apartment with
Laura C., who occasionally used Joy C.’s name instead of her own.
After 1986, Laura C.’s infant daughter also lived in the E. 77th
Street apartment.
In July 1989, petitioner arranged to take over an apartment,
located at 320 E. 65th Street in New York, rented by another
individual named Jane M. Ms. M. was allowed to live at the E.
77th Street apartment while the apartment on E. 65th Street was
renovated. Ms. M.’s name remained on the lease for the E. 65th
Street apartment; Real Services was not identified on the lease
document.
2. Unreported Income
For petitioner’s 1989 and 1990 taxable years, respondent
determined unreported income in a number of categories. For
convenience, we discuss the issues presented in each of these
categories in the order they were presented in the deficiency
notice.
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