Jefferson Industries Corp. v. Madison Cty. Bd. of Revision

Summary

The Supreme Court of Ohio reviewed the valuation of a manufacturing facility for real-property tax year 2011. The court held that the Board of Tax Appeals properly exercised discretion in relying on a cost approach and heavy-manufacturing cost schedules, but failed to address potentially material conflicts concerning the appraisal’s cost methodology, depreciation, obsolescence, and comparable sales. The decision was vacated and remanded for further consideration.

Holdings

1. The BTA acted within its discretion in relying on the cost approach because the appraisal also used a sales-comparison approach and a substantial portion of the facility had been constructed relatively recently.
2. The BTA committed no legal error by accepting the appraiser's use of heavy-manufacturing cost schedules and relying on his judgment concerning the property's physical characteristics.
3. Before adopting an appraiser's opinion of value when the record contains potentially material conflicting evidence, the BTA must explicitly address the conflicts and the specific objections bearing on the appraisal.

Questions Presented

1. Whether the BTA acted unreasonably or unlawfully by relying on a cost approach in valuing the property.
2. Whether the BTA erred in accepting the appraiser's use of heavy-manufacturing cost schedules and in rejecting challenges concerning personal property.
3. Whether the BTA was required to address potentially material conflicts and specific objections concerning the appraiser's cost approach and sales comparables before adopting that appraisal.

Disposition

reversed_and_remanded