United States Tax Court January 14, 1970, Docket Nos. 4997-67, 4998-67 (Buckeye Union Casualty Co. v. Commissioner)

lead-opinion

OPINION

This case presents for the first time the issue of the application of section 3376 to the liquidation of an insurance corporation. Section 337 was enacted to eliminate the uncertainties attendant upon the Supreme Court decisions in Commissioner v. Court Holding Co., 324 U.S. 331 (1945), and United States v. Cumberland Pub. Serv. Co., 338 U.S.