Zabetti A. Pappas - Page 60




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          proven otherwise.  Alternatively, the fact that foreclosure did             
          not occur until 1991 indicates that there was no closed or                  
          completed transaction in 1990.  Accordingly, we hold that                   
          petitioner has failed to demonstrate that she is entitled to                
          deductions from income tax with respect to the property in                  
          Hawaii.                                                                     
               B.  Business Expenses in 1990                                          
               Petitioner also claims a deduction in 1990 for the amounts             
          she was required to pay the women who provided escort services              
          pursuant to her arrangements, equal to 50 to 60 percent of gross            
          receipts.  Respondent has allowed a deduction equal to 27.04                
          percent of the amount determined as escort income in 1990 as                
          specific expenses of petitioner’s escort business.  On the same             
          basis as our conclusions for 1989, we find that petitioner has              
          failed to establish that she is entitled to larger deductions               
          than those allowed by respondent.  We therefore hold that                   
          petitioner may deduct 27.04 percent of the amounts we have held             
          were unreported escort income for 1990.                                     
               Petitioner also claims as deductions $220 allegedly paid to            
          third-party contractors in 1990.  The record, however, fails to             
          provide sufficient substantiation for us to permit this                     
          deduction.                                                                  
               Petitioner asserts, and respondent concedes, that petitioner           
          is entitled to a deduction for rent of $3,600 and utility                   






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