Worthington City Schools Bd. of Edn. v. Franklin Cty. Bd. of Revision
Annotate this CaseThis case came before the Supreme Court twice. The property owner challenged the Board of Tax Appeals' (BTA) use of a property’s sale price as an indicator of its value, arguing that it was an unreliable way to value property. The BTA rejected that challenge and adopted use of the sale price. In the first appeal, the Supreme Court held that the BTA failed to give full consideration to whether the sale was "recent" which was one of the criteria that must be satisfied before a sale price may be used to value a property for tax purposes. The BTA responded by relying solely on the temporal proximity of the sale to the tax-lien dates. Because proximity was not the only factor affecting recency, and because the property owner made a persuasive argument, the Supreme Court vacated the BTA's decision and remanded the case for a proper determination of "recency" based on the entire record. BTA then issued its decision on remand. The BTA again adopted the sale price as the value of a property based on a conclusion that "recency" had not be rebutted. The property owner appealed again to the Supreme Court, arguing that the BTA disregarded the Supreme Court's earlier holding. The Supreme Court reviewed the BTA's findings of fact and found that its decision was "reasonable and lawful," and that it "fulfilled the instruction of the Court." The Court affirmed the decision of the BTA.
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