Hoosier Casualty Co. v. Commissioner

*1354OPINION.

Milliken:

The petitioner contends (1) that since the policyholders of the Mutual Company had the right to subscribe for stock in the Stock Company the latter was essentially the same as the former; (2) that from January 18,1921, to January 22,1921, the Stock Company was a life insurance company as that term is defined in section 242 of the Revenue Act of 1921; (3) that if the Stock Company was, when it took over the risks of the Mutual Company, an insurance *1355company other than a life or mutual insurance company and therefore falls under section 246 of the Revenue Act of 1921, then…