William H. Johnston and Nancy S. Johnston - Page 3

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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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