Olentangy Local Schools Bd. of Edn. v. Delaware Cty. Bd. of Revison

Summary

The Fifth District Court of Appeals of Ohio affirmed the Ohio Board of Tax Appeals' decision reinstating the Delaware County Auditor's original valuations of two parcels for tax year 2008. The court held that Cheshire Developers failed to prove entitlement to a reduction based solely on comparison with another parcel and that the school board met its burden by demonstrating the inadequacy of Cheshire's valuation approach.

Holdings

1. A taxpayer's unsupported comparison of the tax valuation of another allegedly similar parcel is insufficient to prove the subject property's actual value or justify a reduction in valuation.
2. The taxpayer bears the burden of proving its right to a reduction in the taxable value of the property.
3. The school board satisfied its burden by demonstrating that the taxpayer's valuation approach was flawed and seeking reinstatement of the auditor's original valuation; it was not required to present an independent valuation after the taxpayer's proposed valuation was rejected.
4. The Board of Tax Appeals did not abuse its discretion by rejecting Cheshire Developers' valuation evidence and reinstating the auditor's original assessments.

Questions Presented

1. Whether the Board of Tax Appeals acted unreasonably or unlawfully by rejecting Cheshire Developers' comparison to an adjacent or similarly situated parcel used for roadway purposes.
2. Whether the Board of Tax Appeals erred by failing to accept Cheshire Developers' evidence of value.
3. Whether the Olentangy Local Schools Board of Education failed to satisfy its burden because it presented no independent valuation evidence.
4. Whether the Board of Tax Appeals properly reinstated the Delaware County Auditor's original valuations.

Disposition

affirmed