WHALEY, Judge.
In this suit for the recovery of income tax, plaintiff's contention is that it filed a timely claim for refund under which it may recover an overpayment determined by the Commissioner for 1929, which the Commissioner has refused to allow on the ground that the claim was not filed within two years from the time the tax was paid as provided in section 322 of the Revenue Act of 1928.
An examination of the facts, which we have set out in some detail...
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