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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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