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Respondent determined that petitioner had unreported escort
income of $2,700 in 1989 and $2,700 in 1990 from an individual
named Richard S. Mr. S. testified that, between 1989 and 1992,
he utilized petitioner’s services “maybe once a month but not
necessarily for all that period of time” and paid $200 per visit.
Petitioner has failed to provide sufficient credible evidence
that Mr. S. paid her less than the amounts determined for the
years in issue. We accordingly sustain respondent’s
determination.
Respondent determined that petitioner had unreported escort
income of $2,350 in 1990 from an individual named Meyer S. Mr.
S. wrote 10 checks to cash during the first half of 1990 for
escort services arranged by petitioner.5 Petitioner deposited
the checks into the Real Services’ account. The 10 checks
totaled $1,450. The $1,450 in Meyer S.’s checks in the record
included $460 in checks that were dishonored, as well as $460 in
checks that replaced the dishonored checks. Thus, the documented
amount that Mr. S. paid petitioner for escort services in 1990 is
$990 ($1,450 less $460). We therefore hold that petitioner
received $990 as payment for the escort services she arranged for
5 Although Mr. S. testified that the checks were payment for
the use of petitioner’s apartment to work on clothing designs,
his testimony was highly implausible in the circumstances and not
worthy of belief. We find that Mr. S. testified falsely in view
of an obvious motive to avoid admitting to the purchase of escort
services.
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