Columbus Board of Education v. Franklin County Board of Revision

We find the BTA’s decision to be unlawful and, consequently, reverse it.

Inner City argues that, under R.C. 5715.19(D), the complaint filed for tax year 1993 continued to be valid for 1996 because the value contested in the 1993 complaint was not finally decided until tax year 1996. The BOE responds that the 1993 complaint did not carry over for tax year 1996 and that Inner City *307needed to file a fresh complaint to contest the 1996 value. We agree with Inner City.

R.C. 5715.19(D) contains carryover-value provisions and continuing-complaint provisions. Cincinnati School Dist. Bd. of Edn. v.…