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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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