- 15 - collected income in the role of agent. On the basis of the record in the instant case, we conclude that during 1990, petitioner received from MBL wage income in the amount of $468,218.34. Respondent has conceded that petitioners are entitled to a decrease in their gross income for 1991 to the tent of $41,512.9 Accordingly, we sustain respondent's determinations. The next issue to be decided is whether petitioners are entitled to a bad debt deduction pursuant to section 166(a)(1) for the worthlessness of an alleged loan. Petitioners argue that the $30,000 payment to Mr. Razon during 1986 was a loan that was made in connection with petitioner's trade or business and that became worthless during 1991. Respondent contends that petitioners have not established that a debtor-creditor relationship existed between petitioner and Mr. Razon. Alternatively, respondent argues that, if a debtor-creditor relationship existed, petitioners have not established that the 9 In their brief, petitioners argued that, for 1991, they are entitled to decrease their gross income to the extent of $87,159, which petitioners allege is an amount that was characterized by a Florida State court as a loan by MBL to petitioner. Respondent, noting the decrease in petitioners' income for 1991 to the extent of $41,512, argues that the issue was not raised in the petition or at trial. We agree. Generally, we do not consider new issues raised for the first time on brief. Rollert Residuary Trust v. Commissioner, 80 T.C. 619, 636 (1983), affd. on other issues 752 F.2d 1128 (6th Cir. 1985); Markwardt v. Commissioner, 64 T.C. 989, 997 (1975); Estate of Mandels v. Commissioner, 64 T.C. 61, 73 (1975). Accordingly, in the instant case, we will not address the issue of excluding the alleged loan in the amount of $87,159 from gross income.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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