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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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