Bowles v. Commissioner

*585 Before JAMES, STERNHAGEN, and TRAMMELL.

FINDINGS OF FACT.

The taxpayer is an individual residing in New York, N.Y. In making his income-tax return for 1921 he deducted from his gross income the following items:

1. An item of $450 as money advanced to his brother for educational expenses;

2. An item of $250 as money contributed to the support of his partially dependent mother;

3. An item of $1,200 as money given in payment of a loan by his grandfather to complete the taxpayer's education.

Item 1 the taxpayer deducts as a bad debt; item 2 as a contribution to his partially dependent mother; and item 3 as a necessary business expenditure. The Commissioner has disallowed all the above items as deductions from gross income and has determined that a deficiency in tax is due in the sum of $154.

DECISION.

The determination of the Commissioner is approved.