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he engaged escort services at least six times at petitioner’s E.
77th Street apartment. The services were provided by women other
than petitioner. Dennis T. recalled the name used by
petitioner’s companion Laura C. and conceded receiving escort
services from her. There are no checks or other documentary
evidence connecting petitioner to any amounts Dennis T. may have
paid for escort services received at the E. 77th Street
apartment, where Ms. C. also resided. Although the evidence
demonstrates a business relationship between petitioner and
Dennis T., it fails to connect her with any of the money he paid
for escort services. We accordingly do not sustain the
determination.
Respondent determined that petitioner had unreported escort
income of $945 in 1989 and $945 in 1990 from an individual named
Michael S. Although Michael S. was a business associate of
petitioner’s and admitted paying for escort services at one of
petitioner’s apartments, the arrangements were made by, and the
money was paid to, Laura C., not to petitioner. The payments for
escort services by Michael S. have not been connected to
petitioner, and we accordingly do not sustain the determination.
Respondent determined that petitioner had unreported escort
income of $1,500 in 1989 and $750 in 1990 from an individual
named Paul G. Mr. G. testified that he paid between $1,500 and
$2,000 to petitioner for escort services during the period of
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