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Because the 1991 extensions, on their face, do not indicate
whether the extension particulars (i.e., taxable years,
assessment dates, outstanding liabilities, and extension
expiration dates) were filled in before or after petitioner
signed them, Appeals Officer Mazaroli’s finding that petitioner
signed completed, not blank, extensions was based upon the
presumption of official regularity. That presumption “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.
Chem. Found., Inc., 272 U.S. 1, 14-15 (1926); see also R.H.
Stearns Co. v. United States, 291 U.S. 54, 63 (1934) (“Acts done
by a public officer ‘which presuppose the existence of other acts
to make them legally operative, are presumptive proofs of the
latter.’”). We have repeatedly applied the presumption to
sustain official acts by the Commissioner of Internal Revenue.
See, e.g., Sego v. Commissioner, 114 T.C. 604, 611 (2000);
Perlmutter v. Commissioner, 44 T.C. 382, 398 (1965), affd. 373
F.2d 45 (10th Cir. 1967); Lillis v. Commissioner, T.C. Memo.
1983-142, affd. 740 F.2d 974 (9th Cir. 1984). In this case,
petitioner relies solely upon his stipulated testimony that,
approximately 2 weeks after he signed the 1991 extensions, he
received his copies from the IRS, which “had been completed with
the statutory period for collection extended to December 31, 2004
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