Cleveland Gear Co. v. Limbach

Appellant no longer challenges the method of valuation; it maintains that the method denies it equal protection of the laws. Appellant did not raise this constitutional challenge during the proceedings before appellee, but argues that, by raising it with the BTA and presenting the facts which support the constitutional claim before appellee, appellant created a record upon which this court may consider this challenge. Although appellant makes the prefatory statement that R.C. 5711.16 is facially discriminatory, its argument stresses the specific facts of record. Thus, appellant’s argument is…