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official regularity that generally applies in the case of a
properly prepared PS Form 3877. Pursuant to that presumption,
“The presumption of regularity supports the official acts of
public officers and, in the absence of clear evidence to the
contrary, courts presume that they have properly discharged their
official duties.” United States v. Chemical Found., Inc., 272
U.S. 1, 14-15 (1926); see Keado v. United States, 853 F.2d 1209,
1213 (5th Cir. 1988); United States v. Zolla, 724 F.2d 808, 810
(9th Cir. 1984); United States v. Ahrens, 530 F.2d 781, 784 (8th
Cir. 1976); Coleman v. Commissioner, 94 T.C. 82, 91 (1990).
In Pietanza v. Commissioner, supra, we were unwilling to
rely on the presumption of official regularity. Critical to our
unwillingness to do so in Pietanza was the failure by the Commis-
sioner to establish the existence of the notice of deficiency
that the Commissioner claimed had been prepared and issued to the
taxpayers involved in that case. See Pietanza v. Commissioner,
supra at 739-742. In contrast, we have found on the record
presented the existence of a final notice of deficiency with
respect to petitioners’ taxable year 1997. The instant record
also contains a properly completed PS Form 3877. That form shows
that on May 5, 1999, respondent mailed to each petitioner by
certified mail a final notice of deficiency with respect to
petitioners’ taxable year 1997 that was addressed to 4425
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