Corporate Exchange Buildings IV & V, Ltd. Partnership v. Franklin County Board of Revision

Partnership contends that the BTA erred in not allocating the purchase price between the two parcels. We disagree.

The amount that the Partnership paid for the two parcels containing Corporate Exchange Buddings IV and V is not in dispute. In addition, the BTA determined that the sale to Partnership was an arm’s-length sale; presumably then, the sale price reflects true value. Walters v. Knox Cty. Bd. of Revision (1989), 47 Ohio St.3d 23, 24, 546 N.E.2d 932, 934. However, the arm’s-length sale price was paid for two separate properties.

The two parcels are not identical. While the amount of land…