Srichai and Pusadee Rungrangsi - Page 15

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          him directly (rather than his accountants) for information about            
          the restaurant.3                                                            
               Petitioners failed to present any credible evidence that shows         
          respondent's determination was erroneous.  Rule 142(a); Welch v.            
          Helvering, 290 U.S. 111 (1933).  In general, we do not look behind          
          the notice of deficiency and consider the actions or determinations         
          of a revenue agent, and we shall not do so here.  See Greenberg's           
          Express, Inc. v. Commissioner, 62 T.C. 324, 327-328 (1974).  Thus,          
          we sustain respondent's determination relating to the                       
          reconstruction of petitioners' income for the operation of Stanton          
          Mexicatessen for each of the years in issue.                                
          Issue 3.  Interest Expenses                                                 
               The third issue for decision is whether petitioners are                
          entitled to investment interest expense deductions for 1992 and             
          1993 (and which, according to the notice of deficiency, have                
          carryover consequences to 1994).                                            
               Respondent disallowed $12,221 of interest expenses in 1992 and         
          $10,277 of investment interest expenses in 1993 as deductions               
          because petitioners failed to substantiate the expenses or                  
          establish their entitlement to such deductions.  Petitioners                
          contend that the disputed interest expenses represent interest paid         
          pursuant to the loans from First International Bank (for the small          

               3    We note that Revenue Agent Chang worked with                      
          petitioners' accountants because Mr. Rungrangsi signed a power of           
          attorney to the accountants.                                                

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