United States Board of Tax Appeals May 16, 1930, Docket No. 31806 (Low v. Commissioner)

*982OPINION.

Trussell:

All of our facts are gleaned from the statements of the petitioner, who took the stand in his own behalf. There is no other evidence.

The contention of the respondent is that the advances to the acquaintance of the petitioner were purely charitable donations or gifts, for the reason that they were made under circumstances which afforded no hope of repayment.