Giddens v. Testa (Slip Opinion)

{¶ 1} This is an appeal from a decision of the Board of Tax Appeals (“BTA”), which affirmed the assessment of appellee, the tax commissioner, of Ohio individual income tax against appellants, Ernest and Louann Giddens, for tax year 2008. The Giddenses resided in Missouri but paid Ohio income tax as owners, through grantor trusts, of shares in a corporation that did some of its business in Ohio. In 2008, that corporation was an “S corporation,” meaning that its income passed through for tax purposes.

{¶ 2} The part of the assessment at issue here involves the tax commissioner’s reduction of the…