Lowe's Home Ctrs., Inc. v. Washington Cty. Bd. of Revision

Summary

The Supreme Court of Ohio vacated the Board of Tax Appeals' valuation decision concerning a Lowe's property for tax year 2013 and remanded the matter. The court held that the Board had not adequately evaluated and weighed the county appraiser's property-rights-conveyed analysis under applicable precedent concerning lease-encumbered comparable properties. The court also held that collateral estoppel precluded relitigation of whether the property was special-purpose in nature.

Holdings

1. The BTA's decision was vacated because the BTA had not sufficiently evaluated and weighed the appraisal's property-rights-conveyed analysis under the applicable legal standards governing the valuation of an unencumbered fee-simple estate.
2. Collateral estoppel precluded inquiry into whether the subject property was special-purpose in nature because that issue had been actually litigated and determined in a prior proceeding involving the same property and, as to the county, a full and fair opportunity to litigate.
3. The BTA did not adopt an unconstitutional present-use valuation because it considered the property's location and regional-hub characteristics rather than treating present use as the sole criterion of value.

Questions Presented

1. Whether the BTA properly accepted the county's appraisal as the most competent and probative evidence of value under R.C. 5713.03 and the court's cases governing adjustments to comparable sales of lease-encumbered properties.
2. Whether collateral estoppel barred relitigation of whether the subject property qualified as a special-purpose property.
3. Whether the BTA adopted an unconstitutional present-use valuation.

Disposition

vacated