Johnson v. McClain

Summary

The Supreme Court of Ohio affirmed the Board of Tax Appeals' decision upholding the tax commissioner's 2016 current agricultural use valuation table. The court held that Ohio Administrative Code 5703-25-34(E) concerns county-auditor assessments rather than the commissioner's adoption of the valuation table. It further held that William S. Johnson failed to prove that the commissioner abused his discretion by not adopting separate values for drained and undrained versions of certain soil types.

Holdings

1. Ohio Adm.Code 5703-25-34(E) governs a county auditor's duties when assessing CAUV property and does not provide a basis for challenging the Tax Commissioner's adoption of the unit-value table.
2. Johnson failed to prove that the Tax Commissioner abused his discretion in adopting the 2016 CAUV unit-value table without separate entries for drained and undrained Crosby, Kokomo, and Patton soils.

Questions Presented

1. Whether Ohio Adm.Code 5703-25-34(E), which addresses a county auditor's treatment of soil types not included in the Commissioner's table, applies to a challenge against the Commissioner's adoption of the table.
2. Whether the Tax Commissioner abused his discretion by failing to adopt separate per-acre values for drained and undrained versions of certain soil types.
3. Whether the differing treatment of soil types in the unit-value table, including possible consideration of artificial-drainage investments for some soils but not others, established an abuse of discretion.

Disposition

affirmed