Olentangy Local Schools Bd. of Edn. v. Delaware Cty. Bd. of Revision (Slip Opinion), 152 Ohio St. 3d 331

Property: land and improvements retained by 7991 Columbus Pike, L.L.C. after selling a condominium unit to Delaware County; disputed acreage and valuation for tax year 2011.
Auditor valuation (2011): $1,550,000; owner (Columbus Pike) filed complaint seeking reduction to $300,000 (relying on BOR’s 2009 reduction and other evidence).
BOR reduced value to $300,000; Olentangy Local Schools Board of Education (BOE) appealed to the Board of Tax Appeals (BTA).
At BOR hearing owner testimony claimed acreage was 10.454 (instead of 11.997) and presented unadjusted comparable sales and evidence of unsuccessful marketing; no expert appraisal submitted.
BTA reversed the BOR, finding the record did not support the $300,000 reduction, and reinstated the auditor’s $1,550,000 valuation; owner appealed to Ohio Supreme Court.
Supreme Court affirmed: owner failed to present competent, minimally plausible evidence to justify lower valuation; Bedford rule did not bar reinstatement because owner’s evidence was not competent/plausible and relied on prior-year BOR decision.

Issue	Plaintiff's Argument (Columbus Pike)	Defendant's Argument (BOE)	Held
Whether BOR’s $300,000 reduction was supported by competent evidence	Owner proved lower value via owner testimony, reduced acreage, comparable sales, and failed sale attempts	Owner’s evidence was not competent or probative (no expert, relied on prior BOR decision, sales unadjusted)	BOR’s reduction unsupported; BTA reasonably reversed BOR
Whether acreage should be 10.454 instead of 11.997 for tax-year-2011 valuation	Conveyances of common elements reduced acreage to 10.454	No documentary proof transfer occurred before tax-lien date; records show 2012 transfers	Owner failed to prove reduced acreage; BTA properly attributed 11.997 acres
Whether owner’s testimony and unsuccessful marketing constituted admissible owner-opinion evidence	Owner’s testimony and failed sale offers show lower market value	Owner did not offer a proper owner’s opinion of value; unaccepted offers and nonexpert comparable analysis are not persuasive	Testimony and failed offers not competent; owner-opinion rule inapplicable
Whether Bedford rule barred reinstatement of auditor’s valuation absent BOE evidence	BTA could not reinstate auditor value because BOE presented no affirmative evidence on appeal	Bedford rule inapplicable when owner’s evidence to BOR is not competent/minimally plausible or BOR committed legal error	Bedford rule did not prevent reinstatement here; BTA properly reinstated auditor value

Bedford Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision, 115 Ohio St.3d 449 (2007) (Bedford rule: BTA generally may not reinstate auditor value when BOR reduced value based on owner’s competent, plausible evidence)
Olmsted Falls Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision, 122 Ohio St.3d 134 (2009) (BTA must independently weigh evidence; prior-year valuations not competent proof of current value)
Columbus City School Dist. Bd. of Edn. v. Franklin Cty. Bd. of Revision, 90 Ohio St.3d 564 (2000) (appellant school board bears burden on appeal; BTA required to reverse unsupported BOR reductions)
Worthington City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision, 140 Ohio St.3d 248 (2014) (nonexpert owners generally cannot offer comparable-sales testimony as appraisal evidence)
Dublin City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision, 147 Ohio St.3d 38 (2016) (clarifies Bedford: rule applies only when owner’s BOR evidence is competent and minimally plausible)
Gupta v. Cuyahoga Cty. Bd. of Revision, 79 Ohio St.3d 397 (1997) (BTA need not assign weight to testimony about unaccepted offers)
Smith v. Padgett, 32 Ohio St.3d 344 (1987) (owner-opinion rule: owners may testify to market value if giving an opinion)
Fogg-Akron Assoc., L.P. v. Summit Cty. Bd. of Revision, 124 Ohio St.3d 112 (2009) (rejecting carryover of prior-year valuations absent statutory basis)