20 in Washington, D.C., on June 13, 1994. Under our Rules, petitioner's motion is untimely and will be denied.5 Furthermore, we generally will not look behind a notice of deficiency to examine it for the motives or methods which were used by the Commissioner in arriving at the deficiency determination. Greenberg's Express, Inc. v. Commissioner, 62 T.C. 324 (1974); Senter v. Commissioner, T.C. Memo. 1995-311. Petitioner has not made any showing that information concerning the method by which respondent selected and examined petitioner's returns for 1988 and 1989 is relevant to the subject matter of this case, or is calculated to lead to discovery of admissible evidence. To reflect the foregoing, An appropriate order denying petitioners' motion for discovery will be issued, and decision will be entered under Rule 155. 5 Petitioner filed a Memo to the Court on May 23, 1994, requesting that the Court order respondent to produce and turn over to petitioner documents relating to the examination of petitioners' returns. We do not recognize this Memo as a formal discovery motion; however, had we done so, the request would also have been untimely under Rule 70(a)(2).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011