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for maintaining frivolous or groundless positions. We hold that
they are in the amount stated below.
Section references are to the Internal Revenue Code as
amended. References to petitioner are to William H. Johnston.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners were married and lived in Texas during the years
in issue and when the petition was filed.
Petitioners received the following amounts of income:
1994
Description Amount Source
Wages $22,109 Flour Daniel, Inc.
Wages 8,416 Aeroteck
Interest 348 All American
Social Security 8,331 U.S. Treasury
Pension 155 International Brotherhood of
Electrical Workers
Pension 2,816 Dixie National Life Insurance,
Co.
Total $42,175
1996
Description Amount Source
Wages $47,300 Lebarge & Associates, Inc.
Wages 10,295 Apollo Industrial Services,
Inc.
Wages 3,653 Austin Industries, Inc.
Wages 2,211 Cleveland Inspection Service,
Inc.
Interest 264 All American
Unemployment 1,554 State of Texas
compensation
Social Security 3,030 U.S. Treasury
Pension 468 International Brotherhood of
Electrical Workers
Pension 3,382 Dixie National Life Insurance,
Co.
Total $72,157
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Last modified: May 25, 2011