- 34 - petitioner’s contention that this $1,300 was a loan to her (or Real Services) from Jennifer R. On the basis of the record in this case as a whole, we do not believe that all of this money belonged to Jennifer R. so that she could “lend” it to petitioner. The credible testimony of other witnesses establishes that single payments of this magnitude were sometimes made for escort services arranged by petitioner when the occasion was a “party” involving several customers. We infer that this $1,300 payment was for escort services in addition to those provided by Jennifer R. personally. In addition, the record as a whole also establishes that when petitioner arranged for other women to provide escort services, she did not do so for free. Therefore, we believe that the check signed over to petitioner by Jennifer R. included petitioner’s “brokerage” fee for the transaction she had arranged. In sum, we are satisfied that the evidence supports, and petitioner has demonstrated no error in, respondent’s determination. We accordingly sustain it. Respondent determined that petitioner had unreported escort income of $1,200 in 1989 and $1,200 in 1990 from an individual named Douglas B.; $1,440 in 1989 and $1,680 in 1990 from an individual named Jerrold M.; $1,050 in 1989 and $1,050 in 1990 from an individual named William C.; and $400 in 1989 and $600 in 1990 from an individual named Takero O.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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