Columbus City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision (Slip Opinion)
144 Ohio St. 3d 549
Ohio2015Background
- Taxpayer Donald Beck challenged the 2010 auditor valuations of three two-family rental properties in Columbus (Tulsa Dr., Kingshill Dr., Norma Rd.).
- At the Franklin County Board of Revision (BOR) hearing, Beck testified about rents and submitted printouts of nearby sales (comparables) and relied on a real-estate agent’s input; the agent did not testify.
- The BOR reduced each property’s valuation (to intermediate amounts) for tax years 2010–2012, stating it relied on the sales-comparison and income approaches, but it did not place any supporting computations or appraisal evidence in the record.
- The Columbus City Schools Board of Education (BOE) appealed to the Board of Tax Appeals (BTA); the BOE filed notices of appeal but did not file briefs or appear at the BTA hearing.
- The BTA affirmed the BOR’s reductions, relying on the record and principles from Dublin City Schools v. Franklin Cty. Bd. of Revision; the BOE appealed to the Ohio Supreme Court.
Issues
| Issue | Plaintiff's Argument (BOE) | Defendant's Argument (BOR/BTA/Taxpayer) | Held |
|---|---|---|---|
| Whether the BTA erred by affirming BOR reductions when BOR did not place underlying valuation evidence in the record | BTA must set aside BOR reductions and reinstate auditor’s valuations if no evidence supporting BOR’s valuation is in the record | BOR/BTA relied on the existing record and taxpayer evidence; BOE failed to present contrary evidence or argument at BTA | The BOE waived this claim by not raising it before the BTA; affirmation of BOR reductions was not error |
| Whether the BTA was required to make detailed factual findings about true value | BOE argued BTA must determine and state the facts supporting true value | BTA said it relied on the BOR’s action and the absence of BOE opposition | Court held no requirement for further findings under these circumstances |
Key Cases Cited
- Dublin City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision, 139 Ohio St.3d 193 (2013) (BTA may not reinstate auditor value when taxpayer presents contrary evidence and no evidence supports auditor value)
- Bedford Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision, 115 Ohio St.3d 449 (2007) (same principle limiting reinstatement of auditor valuation)
- LTC Properties, Inc. v. Licking Cty. Bd. of Revision, 133 Ohio St.3d 111 (2012) (noting waiver of issues not raised in earlier administrative proceedings)
- Plain Local Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision, 130 Ohio St.3d 230 (2011) (applying waiver principle to board-of-revision appeals)