In his notice of deficiency respondent determined deficiencies in petitioners' Federal income tax for the years 1957 and 1958 in the respective amounts of $37,017.91 and $35,189.10. The deficiencies are based upon respondent's determinations that Columbia Reporting Co., a sole proprietorship owned by Fred J. Sperapani, was not entitled to be taxed as a domestic corporation pursuant to section 1361 of the Internal Revenue Code of 1954,
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