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BUCKEYE UNION CASUALTY CO. v. COMMISSIONER

Docket Nos. 4997-67, 4998-67.

54 T.C. 13 (1970)

THE BUCKEYE UNION CASUALTY COMPANY AND SUBSIDIARY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. THE BUCKEYE UNION FIRE INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 14, 1970.

Attorney(s) appearing for the Case

John W. Christensen, George D. Massar, and Richard J. Brentlinger, for the petitioners.

Conley G. Wilkerson, for the respondent.

WITHEY, Judge:

The Commissioner determined deficiencies of $4,231,648.22 and $4,467,007.931 for the taxable year 1965 of the Buckeye Union Casualty Co. and its subsidiary and the Buckeye Union Fire Insurance Co., respectively. The cases were consolidated for purposes of trial.

Due to certain concessions made by the parties, the sole issue remaining for decision is whether the gain realized by petitioners for which the deficiencies...

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