Bug filled https://entityframework.codeplex.com/workitem/2418.
The DbCommand itself has zero unmanaged resources, but allocates something on server side. And server will keep that allocated, at worst, until the connection is closed. So it's not a critical issue not to dispose the command, at least if the connection closing will shortly follow. But it's not a good idea either. I would vote for clean approach, we don't know what other ADO.NET providers will do.
The DbCommand itself has zero unmanaged resources, but allocates something on server side. And server will keep that allocated, at worst, until the connection is closed. So it's not a critical issue not to dispose the command, at least if the connection closing will shortly follow. But it's not a good idea either. I would vote for clean approach, we don't know what other ADO.NET providers will do.