OPINION.
ARUNDELL, Judge:
Respondent, in Docket Nos. 86992 and 86993, determined for assessment against each of the petitioners, James Poro and Katherine Poro, the amount of $14,191.25 (being a deficiency in income tax of $11,353 against East Islip Theatre, Inc., for the calendar year 1956, plus an addition to tax of $2,838.25 under section 6651, I.R.C. 1954, for failure to file tax return), plus...
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