GREEN, Judge.
The findings show that the matter of the application of the overpayments for the years 1916, 1917, and 1918 in the total amount of $4,302.99 was not finally determined by the Commissioner until June 26, 1924, when he directed the collector to apply the amount of these overpayments to the balance due on the 1920 taxes. While some further action was taken with reference to the balance then remaining on the 1920 taxes, no further action was taken with reference...
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