Craig S. Walquist & Maria L. Walquist v. Commissioner

152 T.C. No. 3

UNITED STATES TAX COURT CRAIG S. WALQUIST AND MARIA L. WALQUIST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25257-17. Filed February 25, 2019. R through his Automated Correspondence Exam system determined, for Ps’ 2014 tax year, a deficiency in tax and a penalty for an underpayment attributable to a substantial understatement of income tax. R’s computer program generated a 30-day letter inviting Ps to reply and submit relevant information. When Ps declined to respond, the program generated and issued to them a notice of defic- iency in the form of a…