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).
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