Zabetti A. Pappas - Page 33




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               Respondent determined that petitioner had unreported escort            
          income of $540 in 1990 from an individual named Harvey K.  Mr.              
          K.’s testimony supports the determination in full, in that he               
          recalled paying petitioner for escort services on three or four             
          occasions in 1990, estimated the cost at between $100 and $200,             
          and acknowledged a check paid in one instance in 1990 for $180.             
          Respondent’s determination of $540 is three times this figure.              
          We do not accept petitioner’s contention that she and Mr. K. were           
          having an affair and that any escort-related activities involved            
          were independent of his giving her money.  We accordingly sustain           
          respondent’s determination.                                                 
               Respondent determined that petitioner had unreported escort            
          income of $1,300 in 1990 from an individual named Crihil I.  A              
          check for $1,300 issued by Mr. I. on November 10, 1990 to                   
          Jennifer R. and/or cash was endorsed by Jennifer R. to Real                 
          Services and deposited by petitioner into one of her personal               
          bank accounts on November 15, 1990.  Mr. I. did not testify and             
          Ms. R. is deceased.                                                         
               Jennifer R. was one of the women who provided escort                   
          services to customers pursuant to petitioner’s arrangements                 
          during the years in issue.  In these circumstances, and in light            
          of the other proof that petitioner was regularly engaged in the             
          provision of escort services in 1990, we conclude that this check           
          was for escort services arranged by petitioner.  We reject                  






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