Zabetti A. Pappas - Page 34




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          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.                                     








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