Willoughby Hills Dev. & Distrib., Inc. v. Testa (Slip Opinion)

*277 {¶ 1} Appellant, Willoughby Hills Development and Distribution, Inc. ("WHDD"), appeals a Board of Tax Appeals ("BTA") decision that affirmed appellee tax commissioner's denial of WHDD's request for a commercial-activity-tax ("CAT") refund. Subject to certain exclusions, the CAT is levied on each person or entity with taxable gross receipts above a certain threshold for the privilege of doing business in Ohio. See R.C. 5751.01 et seq. The issue here involves whether WHDD can meet the requirements of a gross-receipts exclusion that applies when a person or entity acts as an agent for *838 another.…