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of $26,056, tax withheld from petitioner’s wages of $2,344,
estimated tax payments of $255, and tax due of $23,457.
On April 17, 1996, petitioner filed with the Internal
Revenue Service (IRS) a return for her taxable year 1994 (peti-
tioner’s 1994 return).3 Petitioner did not request or receive an
extension of time within which to file petitioner’s 1994 return.
On June 24, 1996, almost 2 years after petitioner and Mr.
Castle signed the 1993 joint return, they filed it with the IRS.
At the time they filed the 1993 joint return, petitioner and Mr.
Castle did not pay the tax due shown in that return.
On August 19, 1996, respondent assessed the following
amounts with respect to the 1993 joint return: Tax of $26,056,4
penalties of $8,654.47, and interest of $6,290.61.
At a time not disclosed by the record, but prior to June 2,
1998, petitioner and Mr. Castle separated. Thereafter, on June
2, 1998, petitioner and Mr. Castle signed a property settlement
agreement (property settlement agreement). That agreement
provided, inter alia:
12. The parties hereto do make the following division
and settlement of their property:
A. Wife [petitioner] shall receive as her sole
and separate property:
3The record does not disclose whether petitioner filed that
return jointly with Mr. Castle.
4Respondent credited $2,344 of withholding shown in the 1993
joint return against the tax assessed.
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