Zabetti A. Pappas - Page 6

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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             
          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               

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