- 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.
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