Sears, Roebuck & Co. v. Franklin Cty. Bd. of Revision (Slip Opinion), 144 Ohio St. 3d 421

Sears owned a 16.71-acre Eastland Mall parcel with a 225,882 sq ft department store and a 53,362 sq ft automotive center (total 279,244 sq ft); second floors largely unused.
Franklin County auditor valued the property at $8,323,000 for tax year 2005 (reappraisal year) and for 2006–2010.
At the BOR hearing Sears offered a non-expert company valuation; BOR gave it little weight and retained the auditor’s valuation.
Sears appealed to the Board of Tax Appeals (BTA) and submitted a certified-appraiser report (Fried) valuing the property at $6,300,000 (2005) and $6,550,000 (2008), treating the department store and auto center as one economic unit.
Columbus City Schools (school board) cross‑examined, submitted county website printouts of five auto-service sales as rebuttal, but offered no expert rebuttal or appraisal review.
The BTA adopted Fried’s appraisal as the sole competent and probative valuation; the school board appealed to this court.

Issue	Plaintiff's Argument (School Bd.)	Defendant's Argument (Sears / BTA)	Held
Whether the BTA must issue detailed findings of fact/conclusions of law	BTA erred by not setting forth relevant facts and explaining which evidence it relied on	BTA need not make particularized findings; it may adopt the sole competent appraisal in the record	The court held BTA has no duty to issue particularized findings; decision lawful and reasonable
Admissibility/probative weight of appraisal (comparables)	Fried’s use of department-store comparables is not probative because the auto center differs and comparables aren’t truly comparable	Fried gave reasons for treating both buildings as one economic unit; comparables justified and not rebutted by expert evidence	The court upheld BTA’s adoption of Fried’s appraisal; comparables challenge insufficient to reverse
Whether BTA had to address every argumentative criticism by counsel	BTA must address criticisms	Only conflicting evidence (e.g., another appraisal or expert appraisal review) requires detailed engagement	The court held counsel’s speculations are not equivalent to competing expert evidence; BTA need not discuss every contention
Whether highest-and-best-use argument can be raised on appeal	School board contends highest-and-best-use finding unsupported	Argument was not raised below or in the notice of appeal	Court held that highest-and-best-use argument is jurisdictionally barred on appeal

Wolf v. Cuyahoga Cty. Bd. of Revision, 11 Ohio St.3d 205 (1984) (BTA not required to make separate findings of fact and conclusions of law)
Wheeling Steel Corp. v. Evatt, 143 Ohio St. 71 (1944) (no authority requiring separate findings and conclusions)
Strongsville Bd. of Edn. v. Cuyahoga Cty. Bd. of Revision, 77 Ohio St.3d 402 (1997) (endorsing unified treatment of separate buildings as an economic unit)
Park Ridge Co. v. Franklin Cty. Bd. of Revision, 29 Ohio St.3d 12 (1987) (upholding treatment of apartment complexes as economic units)
Vandalia-Butler City School Dist. Bd. of Edn. v. Montgomery Cty. Bd. of Revision, 106 Ohio St.3d 157 (2005) (BTA may discredit sole appraisal when unconvincing)
Gen. Motors Corp. v. Cuyahoga Cty. Bd. of Revision, 67 Ohio St.3d 310 (1993) (BTA must explain basis when it adjusts between competing appraisals)
Villa Park Ltd. v. Clark Cty. Bd. of Revision, 68 Ohio St.3d 215 (1994) (same principle requiring explanation when BTA departs from submitted appraisals)
Dublin Senior Community L.P. v. Franklin Cty. Bd. of Revision, 80 Ohio St.3d 455 (1997) (BTA must consider multiple appraisals in the record and explain acceptance or rejection)
Howard v. Cuyahoga Cty. Bd. of Revision, 37 Ohio St.3d 195 (1988) (discussing when BTA should state what evidence it found relevant)
HealthSouth Corp. v. Levin, 121 Ohio St.3d 282 (2009) (applies Howard; BTA should identify relevant evidence when needed)