- 32 -
named Michael L. Mr. L. testified to paying substantial sums for
escort services in 1989 and 1990 that were provided in
petitioner’s E. 77th Street apartment. He could not, however,
identify petitioner in person, and he was uncertain whether a
person he knew as “Angel” was the person depicted in a photograph
of petitioner taken close to the years in issue. He described
the “Angel” with whom he had dealings as a person who bears
little resemblance to petitioner. The record before us fails to
provide an adequate basis for finding that petitioner, rather
than some of her associates, received unreported income in the
form of direct payment for escort services from Mr. L. during the
years at issue. The evidence nevertheless supports a finding
that petitioner received $4,000 in escort income from Mr. L., and
that she received this amount in 1990. In the summer of 1990,
Mr. L. lent $4,000 to “Real Services Corp.” Two months later,
petitioner signed and issued a check, presumably in repayment,
for $4,800. The check was dishonored, and Mr. L. acknowledged
that his loan was “most probably” repaid in the form of escort
services. Although Mr. L. did not pay petitioner directly for
escort services, petitioner’s signature on the invalid check
nevertheless connects her to the receipt of $4,000 in 1990 in
exchange for which Mr. L. received such services. We accordingly
sustain respondent’s determination only to the extent of $4,000
of unreported escort income in 1990.
Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: May 25, 2011