- 33 - 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 rejectPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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