- 64 - “most probably” repaid in the form of escort services. We held that petitioner derived $4,000 in escort income from this transaction. This evidence does not demonstrate that petitioner is entitled to an interest deduction. Petitioner also claims a deduction for interest paid to Vania W., as a result of a $2,500 “loan” made to her by Ms. W. “for investment purposes” in February 1990. However, the documents petitioner offered in support of the claimed interest payments are not competent evidence for this purpose,21 and Ms. W. did not testify. Petitioner has failed to prove the amount of any repayment to Ms. W. that may have occurred, or the amount of principal repayment versus interest. Petitioner claims a $200 interest deduction with respect to a loan from Phillip B., but undercuts that claim with other testimony to the effect that this loan was to be one with “no interest”. She additionally claims that, if we find that she was in the escort business, she is entitled to an interest deduction of $875 for escort services provided to Ronald K. His testimony, however, is that she provided the services (less frequently than she now claims) only as a favor. Once again, this testimony fails to support a finding that petitioner incurred a deductible 21 Ms. W.’s written statements regarding repayment were excluded as hearsay, and the checks that petitioner claims reflect repayment to Ms. W. were made out to petitioner herself or cash.Page: Previous 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 Next
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