Per Curiam.
We affirm the BTA's decision.
Former R.C. 5747.11 sets forth the statute of limitations for applying for refunds of income tax:
"(A)(1) The tax commissioner shall refund to employers or taxpayers, with respect to any tax imposed under this chapter or Chapter 5748. of the Revised Code:
"(a) Overpayments of more than one dollar;
"(b) Amounts in excess of one dollar paid illegally or erroneously;
"* * *
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