Worthington City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision

Summary

The Supreme Court of Ohio reviewed a Board of Tax Appeals decision adopting the May 2003 sale price of a commercial property as its taxable value for tax years 2004 and 2005. The court held that the complaint was not barred by Ohio Revised Code 5715.19(A)(2), and that collateral estoppel did not apply. It vacated and remanded because the Board of Tax Appeals failed to fully consider whether the sale remained recent in light of changes affecting the property and market.

Holdings

1. The complaint was not barred because the May 2003 arm's-length sale occurred after the lien date for the prior tax year, its effect had not been considered in the prior valuation because construction was incomplete, and the completion of the buildings constituted a substantial improvement before the 2004 lien date.
2. The board of revision's decision not to use the May 2003 sale price for tax year 2003 did not collaterally estop consideration of that sale price for tax year 2004.
3. A recent arm's-length sale price must ordinarily be considered the value of the property, subject to rebuttal concerning whether the sale was recent and whether it was an arm's-length transaction.
4. The BTA erred by considering only the temporal proximity of the May 2003 sale to the 2004 lien date and failing to consider evidence of changed circumstances bearing on recency as of both the 2004 and 2005 lien dates.

Questions Presented

1. Whether R.C. 5715.19(A)(2) barred the school board's complaint for tax year 2004 as a second complaint filed within the same three-year interim period.
2. Whether the board of revision's treatment of the May 2003 sale price in valuing the property for tax year 2003 had collateral-estoppel effect on the valuation for tax year 2004.
3. Whether the Board of Tax Appeals adequately considered whether the May 2003 sale was recent as of the January 1, 2004 and January 1, 2005 lien dates.
4. Whether the BTA's adoption of the May 2003 sale price was supported by the evidence and consistent with the school board's burden of proof.

Disposition

vacated