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in 1990. We accordingly sustain respondent’s determination to
that extent.
Respondent determined that petitioner had unreported escort
income of $1,400 in 1989 and $200 in 1990 from an individual
named Alexander K. The evidence with respect to these specific
items consists of Mr. K.’s check for $1,200 made out to Real
Services, dated October 12, 1989, which petitioner deposited into
the Real Services’ account; petitioner’s possession of Mr. K.’s
business card; Mr. K.’s testimony that he did not purchase escort
services from petitioner in 1989 or 1990, but that he entered
only the amount on the check and signed it; and petitioner’s
claim that the check was in payment for space for an office
party. Petitioner’s claim is uncorroborated; the amount is
improbable for the use of residential apartment space for a
party; and she is otherwise not credible. Given the other proof
of petitioner’s extensive dealings in providing escort services
in 1989, we find that the $1,200 payment in October 1989 was for
escort services. There is no other evidence that petitioner had
the specific items of income determined by respondent or which
connects petitioner to any payments from Mr. K. for any goods or
services. We accordingly sustain respondent’s determination only
to the extent that petitioner had unreported escort income of
$1,200 in 1989.
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