LITTLETON, Judge.
The facts in this case disclose that the claim filed December 12, 1922, was disallowed and rejected in its entirety by the Commissioner May 19, 1925, and that no formal claim for refund was filed within five years after the return for 1921 was due. The claim of April 23, 1929, was filed after the expiration of the statute of limitation for filing claims and, inasmuch as Treasury Decision 4235 was not complied with by the filing of an application...
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