MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Beverly Theaters, Inc. (Beverly) and M.I.C. Ltd. (MIC), petitioned the Court to redetermine respondent's determinations with respect to their Federal income taxes. Respondent's determinations for MIC are reflected in a notice of deficiency dated December 8, 1993, and the determinations for Beverly are reflected in a notice of deficiency dated June 2, 1994. Respondent's determinations are as follows:
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