- 60 - 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 utilityPage: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 Next
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