Zabetti A. Pappas - Page 28

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          their relationship, which he estimated to be approximately 2                
          years.  His testimony and the documentary evidence support the              
          conclusion that he paid most of this amount in 1989, but that the           
          relationship continued into 1990.  On the basis of his testimony,           
          we find that petitioner received $1,500 from Mr. G. in 1989 and             
          another $500 in 1990.  We accordingly sustain all of respondent’s           
          determination except to the extent of $250 in 1990.                         
               Respondent determined that petitioner had unreported escort            
          income of $10,500 in 1989 and $3,900 in 1990 from an individual             
          named Jeffrey F.  The evidence adduced in connection with this              
          determination conflicts to some extent with the specific items of           
          income determined by respondent.  Mr. F. recognized the name Real           
          Services as the payee of checks he used to acquire escort                   
          services for his clients.  The record contains one check from him           
          for $200 that petitioner deposited.  Mr. F. also testified that             
          he paid between $5,000 and $15,000 to a woman named “Angel”, one            
          of petitioner’s nicknames, for escort services for his clients.             
          However, Mr. F. testified that these payments took place over a             
          10-year period during which he also used at least one other                 
          escort service for his clients.  Mr. F. was unable to identify              
          petitioner at trial, or to recall the amount he paid petitioner             
          during the years at issue.  We conclude that the evidence                   
          establishes that Mr. F. paid petitioner $1,500 in 1989 and $1,500           

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