MATTHIAS, J.
The single question raised by this appeal is whether the Board of Tax Appeals had jurisdiction to review the order of the Tax Commissioner. The board found, inasmuch as the Tax Commissioner refused to issue a final assessment certificate, that, under the decision in Willys-Overland Motors, Inc., v. Evatt, Tax Commr., 141 Ohio St. 402, 48 N.E.2d 468, it had no jurisdiction to review the order of the Tax Commissioner.
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