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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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