Internatl. Business Machines Corp. v. Zaino

[This decision has been published in Ohio Official Reports at 94 Ohio St.3d 152.] INTERNATIONAL BUSINESS MACHINES CORPORATION, APPELLANT, v. ZAINO, TAX COMMR., APPELLEE. [Cite as Internatl. Business Machines Corp. v. Zaino,

2002-Ohio-349.] Taxation—Franchise tax—Petition for reassessment—Taxpayer seeking refund of an overpayment of franchise tax must file an application for refund—R.C. 5733.11, construed and applied. (No. 00-1700—Submitted September 19, 2001—Decided January 30, 2002.) APPEAL from the Board of Tax Appeals, No. 99-K-616. __________________ SYLLABUS OF THE COURT When the tax…