Dublin City Schools Board of Education v. Franklin County Board of Revision

Summary

The Ohio Supreme Court, on reconsideration, held that the Board of Tax Appeals correctly rejected a bulk-appraisal valuation for 21 unfinished condominium units because it violated the statutory requirement to treat each condominium unit as a separate parcel and did not reflect true market value. The court held that the Board of Tax Appeals acted unreasonably and unlawfully by reinstating the county auditor’s valuations without independently determining value. The matter was remanded to the Board of Tax Appeals for an independent valuation.

Holdings

1. The BTA correctly rejected East Bank's bulk-value appraisal because Ohio law requires condominium units to be treated as separate parcels for taxation and because the appraisal calculated an investment value rather than the true market value or anticipated open-market sale prices of the individual units.
2. The BTA acted unreasonably and unlawfully by reverting to the auditor's valuations after rejecting East Bank's appraisal; it was required to conduct an independent determination of the taxable value of the properties.

Questions Presented

1. Whether the Supreme Court should reconsider its prior decision because it accepted East Bank's bulk-sale valuation without determining whether that methodology was legally and factually valid.
2. Whether the BTA properly rejected a bulk appraisal that valued 21 separately taxable condominium units as a single economic unit.
3. Whether the BTA acted unreasonably or unlawfully by reinstating the county auditor's valuations instead of independently determining the taxable value of the properties.

Disposition

reversed_and_remanded