I don't know where you got 3 degrees C per W for a TO-3 from. Every TO-3 I've ever used has been somewhere between 0.6 to 0.7 degrees per watt. 3 Degrees per watt is terrible junction to case! ON-semi 3055 is 0.657 degree/W for JC.
Anyway, I can't say I'd use a TO-3 purely for JC thermal resistance. There's almost always a circuit to parallel devices, where you can spread the load across more than one package very cheaply (and in doing so even out the heatsink heat transfer). And for that reason, in our present age, I don't believe JC is the big difference/reason for use.
On the other hand, as I was saying about the package temp rating. If your in an enviroment that has a very high ambient temp (e.g. industrial appllications, automotive, military), it doesn't matter that you've got a low JC resistance, if your heatsink can't effectively dissipate to free air because the free air temp is very high. This is where the TO-3 packages win hands down.
But as a side note, back the original question. If you need to disipate more than what a TO-220 package can handle, you're probably better off looking at one of the many easy circuits to couple a linear regulator with regular cheap NPN transistors to get your desired rating, or even consider a switchmode supply