3535 Salem Corp. v. Lindley

In reversing the Tax Commissioner’s conclusions and finding that the transactions involved' here are nontaxable, the Board of Tax Appeals relied upon the “true object” test originally enunciated by this court in Acountant's Computer Services v. Kosydar (1973), 35 Ohio St. 2d 120, and as reaffirmed in Miami Citizens National Bank v. Lindley (1977), 50 Ohio St. 2d 249.

The board found that the taxpayer “* * * sought as the true object of the transactions with the aerial survey firms the survey information contained on the map. The surveyors were professional engineers and surveyors who not only…