Board of Education of Dublin School District v. Limbach

Ultimately, the issue is whether the BTA’s decision is unreasonable or unlawful. Subsumed within that issue is whether the subject property is *257entitled to tax exemption as property “used * * * as hospital facilities” under former R.C. 140.08.

The school board first contends that the BTA erred in relying on collateral estoppel to conclude that the bond validation proceeding determined that Village is a “hospital facility” as defined in R.C. 140.01(E) because the school board was not a party to, was not served with notice of, and did not participate in, the bond validation proceeding, and…