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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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