Zabetti A. Pappas - Page 7




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               A.  Escort Income                                                      
               Petitioner arranged for the provision of escort services               
          during 1989 and 1990 out of the two apartments noted above, as              
          well as an apartment on W. 58th Street in New York during the               
          latter year.  She received cash and checks in payment for those             
          services.  At her request, many of the checks were drawn to the             
          order of Real Services.                                                     
               Dennis T. engaged escort services at least six times at                
          petitioner’s E. 77th Street apartment.  Mr. T. received escort              
          services from Laura C.  In terms of his direct dealings with                
          petitioner, however, he engaged only in legitimate business                 
          activities.  These included a loan to petitioner for $4,000,                
          which she repaid with a mixture of checks from the Real Services’           
          account and from her personal accounts.                                     
               A business associate of petitioner, Michael S., paid for               
          escort services received at either petitioner’s E. 77th or E.               
          65th Street apartment, approximately six times during 1989                  
          through 1990.  However, the arrangements were made by, and the              
          money was paid to, Laura C.                                                 
               Paul G. paid petitioner $1,500 in 1989 and $500 in 1990 for            
          arranging escort services for him with other women.  Mr. G. also            
          provided investment advisory services for one of the women                  
          providing escort services to him pursuant to petitioner’s                   








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