
    Appeal of J. D. BOWLES.
    Docket No. 245.
    Submitted January 29, 1925;
    decided February 12, 1925.
    
      J. D. Bowles, the taxpayer, in his own behalf.
    
      Arthur H. Fast, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner.
    
      Before James, Sternhagen, and Trammell.
    FINDINGS OE FACT.
    The taxpayer is an individual residing in New York City, 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 Ms 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.  