Talawanda City School Dist. Bd. of Edn. v. Testa (Slip Opinion)

{¶ 1} In this real-property-tax exemption case, the tax commissioner found that a portion of the property owned by the Talawanda City School District Board of Education (“BOE”) was not used for school purposes, and he denied the claim of exemption as to that portion of the property. The Board of Tax Appeals (“BTA”) affirmed, and the BOE has appealed.

{¶ 2} On its face, R.C. 3313.44 permits exemption based solely on ownership by the BOE. The dispute in this appeal centers on whether the statute nonetheless also requires that the property be used exclusively for school purposes. We hold that…