- 35 -
In 1989, petitioner deposited a check payable to Real
Services from Douglas B. for $400. During 1990, petitioner
deposited into her Chemical Bank accounts two checks to cash
totaling $225 from Jerrold M., a check to cash for $200 from
William C., and two checks payable to cash totaling $140 from
Takero O. Petitioner claims that the $400 check from Douglas B.
represents repayment of a loan. She argues that she got two
checks from Jerrold M. for helping him to find his girlfriend.
She claims not to know William C. and that she got his $200 check
from a third party for room rental. She says the two checks
totaling $140 from Takero O., plus $10 cash, were payment for
tickets to a Broadway show. We do not accept her self-serving
testimony. See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
To the contrary, in light of the other substantial evidence that
petitioner was in the business of providing escort services for
compensation during 1989 and 1990, her deposit of checks made out
to Real Services or to cash from Douglas B., Jerrold M., William
C., and Takero O. is sufficient, we conclude, to support the
finding that these six checks were payments to her for the
provision of escort services. On the other hand, these
individuals did not testify, and there is no evidence in the
record that petitioner had any specific items of income from
these individuals beyond the amounts evidenced by the checks. We
accordingly hold that petitioner had unreported escort income in
Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: May 25, 2011