Nicholas A. and Marjorie E. Paleveda - Page 15

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          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.                                                          




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