Campanella v. Lindley

Broadly speaking, we are faced with the question of whether a county auditor may appeal the Tax Commissioner’s apportionment, among the various counties and taxing districts of the state, of the value of property owned by a telephone company.

The Board of Tax Appeals (board) based its determination that it had no jurisdiction, and dismissed appellant’s appeal, on alternative grounds. First, the board ruled that the apportionment was not a determination, finding, computation, or order, as those terms are used in R. C. 5717.02; thus, it was stated by the board, the apportionment was not an…