250 Shoup Mill, L.L.C. v. Testa (Slip Opinion)

{¶ 1} The appellant property owner, 250 Shoup Mill, L.L.C. (“Shoup”), applied to exempt real property used as a public “community school” for tax year 2010. Shoup challenges a decision of the Board of Tax Appeals (“BTA”) that affirmed the tax commissioner’s denial of exemption to the property that Shoup leased to *99the community school. Shoup itself is wholly owned by a 501(c)(3) nonprofit corporation whose members include the very community school to whom the property is leased. Shoup argues that the nonprofit and charitable character of the ownership arrangement decisively distinguishes this…