(2)The Commissioner shall, after making such inquiries or calling for such information as he may deem necessary, notify to the liquidator within there months from the date on which he received the intimation of the appointment of the liquidator, the amount which, in the opinion of the Commissioner, would be sufficient to discharge the liability of the company for any tax including interest and penalty, if any, which is then, or is likely thereafter to become, payable by the company.
