Zabetti A. Pappas - Page 18

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          petitioner’s repayment checks bounced, however, or were                     
          reinvested, on the basis of petitioner’s representation that she            
          would invest this money in real estate on behalf of Tammy M.                
          Tammy M. recovered the amount of her loan to petitioner, but she            
          received no more than that.                                                 
               In another transaction in early 1990, petitioner received              
          $2,500 from Vania W.  Petitioner executed a letter memorandum               
          dated February 3, 1990, acknowledging her receipt of $2,500 from            
          Vania W., which she promised to invest and to repay in 30 days              
          with $1,000 interest.  Petitioner subsequently wrote two checks             
          in March 1990 totaling $2,650 on a Real Services’ account, made             
          payable to herself or to cash.  Although the memorandum line on             
          the checks indicated that they were executed as a “return” or               
          “replacement” for Ms. W., each check was endorsed only by                   
          petitioner herself.                                                         
               In the summer of 1990, petitioner borrowed $2,500 from a               
          tennis-playing partner named Phillip B.; he charged her no                  
          interest on the loan.  She made substantial repayments a few                
          months later.                                                               
          5.  Petitioner’s 1991 and 1992 Taxable Years                                
               For the last two years in issue, 1991 and 1992, respondent             
          determined petitioner’s unreported income by applying cost-of-              
          living survey information published by the Bureau of Labor                  
          Statistics (BLS).  Respondent used BLS tables that classify the             

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