MCI Telecommunications Corp. v. Limbach

*197A

Specifying Error in the Notice of Appeal

In paragraph four of its notice of appeal filed with the BTA, MCI asserted that the commissioner’s application of R.C. 5727.10 to it denied it equal protection of the laws, and, in paragraph five, that the commissioner’s failure to apply the general personal property tax statute to it, R.C. 5711.22, also denied it equal protection. The commissioner, in her Proposition of Law No. Ill, asserts the notice of appeal was specific enough to challenge the statutes on their face but not specific enough to challenge them as applied to MCI. MCI, in its…