Per Curiam.
Section 5703.05, Revised Code, gives the Tax Commissioner power to issue a certificate of abatement for taxes overpaid, "on written application of any person * * * claiming to have overpaid to the Treasurer of State at any time within five years prior to the making of such application."
Section 5728.061, Revised Code, authorizing the Treasurer of State to refund highway use taxes illegally or erroneously paid, provides that "an application...
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