John A. Roberts - Page 13

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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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