The opinion
Appeal of J. D. BOWLES.
Bowles v. Commissioner
Docket No. 245.
United States Board of Tax Appeals
1 B.T.A. 584 ; 1925 BTA LEXIS 2872 ;
February 12, 1925 , decided Submitted January 29, 1925 .
*2872 J. D. Bowles, the taxpayer, in his own behalf.
Arthur H. Fast, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the 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.