- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011