QUESTION3.15 (Identificationofuncontrolledpartnershipincome)

TheNortonfamilyoperate thetowngarageandgeneralstoreinSticksville. NevNorton,whobuiltthegaragein1982,hasalwaysoperatedthebusiness inpartnership withthe various members ofhis family.

Underthe terms ofthepartnership agreement,for the 2O21/22 tax year, thepartnershipnet income of$180,000 was sharedequally between eachof thefollowing6partnersfromtheNortonfamily:

• NevalthoughNevisnowsemi-retired,hedraws$1,500perweek.
• Col(Nev's sonaged38)-Colisthemanagerof thebusinessandcontrolsall operations and finances.
• Ruth(Col's wifeaged37)-Ruthrefusesto go anywhere near thebusiness andsplits hertime betweenraisingtheirthreechildren andpart-time employment asabarattendant atthehotel. Although Ruth is afullpartner,sheisnotawareofhowmuchincomeisdistributed toherasNevandColalways electtore-investthe entireamountbackinto thebusiness.
• Mai(Nev's son aged34)Malhasspent thelast18months inSydneyundergoingmedical rehabilitationfollowingahorrific work accident.Untilhereturns towork,Malhasinstructed Coltore-invest allofMai'sdistribution back intothe business.
• Rachel(ColandRuth's daughter aged15) -Rachelattends boarding schoolin Brisbane and isnotinvolved in thebusinessinanyway. Her portionofnetpartnership incomeisalways re-invested, againunder electionby Nevand Col.
• NortonHoldingsPtyLimited(thefamily'sinvestmentcompany).

Givingreasons, whichoftheabovepartners wouldbecharged additional taxunders.94(uncontrolled partnershipincome)?