Chapman Ents., Inc. v. McClain (Slip Opinion), 179 N.E.3d 1201

The Tax Commissioner issued final determinations on April 29, 2020; service was completed May 4, 2020. Under R.C. 5717.02(B) Chapman had 60 days from service to file an appeal to the Board of Tax Appeals (BTA).
Because the 60th day fell on the July 4 holiday, the statutory deadline was effectively July 6, 2020. Chapman delivered a notice of appeal to the tax department on June 26, 2020, and filed with the BTA on July 27, 2020.
The BTA dismissed both appeals as untimely, reasoning that the legislative COVID-19 tolling enacted in 2020 Am. Sub. H.B. 197 did not extend the deadline for appeals to the BTA.
Chapman appealed to the Ohio Supreme Court, arguing H.B. 197 tolled the 60‑day appeal period. Instead of opposing on the merits, the Tax Commissioner filed motions to remand, agreeing H.B. 197 tolled the deadline and that the appeals were timely.
The Supreme Court considered whether H.B. 197 tolled the R.C. 5717.02(B) appeal period, and whether Chapman’s filings satisfied the dual filing requirement (with both the Commissioner and the BTA).
The Court held H.B. 197 tolled the 60‑day appeal period (tolling ran through July 30, 2020), concluded Chapman’s filings were timely, reversed the BTA dismissals, and remanded for merits proceedings.

Issue	Plaintiff's Argument (Chapman)	Defendant's Argument (BTA/earlier position)	Held
Whether 2020 Am. Sub. H.B. 197 tolled the 60‑day statute for filing an appeal from the Tax Commissioner to the BTA under R.C. 5717.02(B)	H.B. 197 tolls administrative time limits, so the 60‑day appeal period was tolled and Chapman’s dual filings (June 26 to Commissioner; July 27 to BTA) are timely	Tolling does not apply to notices of appeal filed with the BTA (BTA dismissed as untimely)	The Court held H.B. 197 tolled the appeal period; Chapman’s appeals were timely; BTA dismissals reversed and cases remanded

Northlake Hills Coop., Inc. v. Collins, 45 Ohio St.2d 13 (filing within statutory period is prerequisite to BTA jurisdiction)
Fineberg v. Kosydar, 44 Ohio St.2d 1 (dual filing requirement and time limits for BTA appeals are mandatory)
Am. Restaurant & Lunch Co. v. Glander, 147 Ohio St. 147 (statutory time limits for appeals to the BTA are mandatory)
Sekerak v. Fairhill Mental Health Ctr., 25 Ohio St.3d 38 (parties cannot create subject‑matter jurisdiction by agreement)
Columbus City Schools Bd. of Edn. v. Testa, 129 Ohio St.3d 200 (court must independently decide jurisdictional issues despite parties’ agreement)