Zabetti A. Pappas - Page 64




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          “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.                                                                    





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