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to the applicability of section 6654, none of which cover
petitioner.
C. Transcripts of Account
Respondent asks us to find from the transcripts of account
that petitioner did not file an income tax return for 2001, he
made no estimated tax payments for that year, and, ultimately, he
is liable for the section 6651(a)(1) and 6654 additions to tax
respondent determined. Petitioner objects to the receipt of the
transcripts of account into evidence on the ground that
respondent failed to properly authenticate them, since the
certificates accompanying them were not dated.
Domestic public records under seal are self-authenticating
pursuant to rule 902(1) of the Federal Rules of Evidence, and
that rule has no requirement that a date accompany the seal and
signature required by the rule. Petitioner offered no authority
to the contrary, and we have found none. We accept the
transcripts of account as authentic.
D. Burden of Production
Respondent bears the burden of production with respect to
the section 6651(a)(1) and 6654 additions to tax. See sec.
7491(c). In order to carry that burden, respondent must produce
sufficient evidence establishing that it is appropriate to impose
the additions. See Higbee v. Commissioner, 116 T.C. 438, 446-447
(2001). Once respondent has done so, the burden of proof is upon
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