LITTLETON, Judge.
With reference to the sufficiency of the claim for refund filed by plaintiff for the fiscal year 1920, the facts clearly establish that the grounds of this claim were those upon which the refunds made and the overpayment of $74,350.90 involved in this case were determined. There is no question as to the amount of the overpayment for 1920. The amount claimed was determined by the Commissioner, but his reason for refusing to schedule this overpayment...
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