Mann Construction Co., Inc. - Page 25

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          so would be futile.  See Andrew v. Commissioner, 54 T.C. at 245-            
          246; Bowman v. Commissioner, supra.                                         
               We hold that the $120,547 of advances petitioner made to               
          Mark Mann on or before July 31, 1991, and the $48,396 of interest           
          petitioner accrued on those advances on or before that date, less           
          the repayments Mark made of $57,046, were bona fide debt that               
          became worthless during petitioner's taxable year ended July 31,            
          1992.  We further hold that the $6,106 in advances made after               
          July 31, 1991, did not constitute bona fide debt and was not                
          eligible for the section 166 bad debt deduction.                            
               To reflect all the foregoing,                                          

                                                  Decision will be entered            
                                             under Rule 155.                          

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