Libby-Owens-Ford Co. v. Collins

Appellant contends that the tin and the assistor rolls are not personal property subject to taxation because of the exclusion from the definition of personal property of “dies” in R. C. 5701.03.

The decision of the Board of Tax Appeals that the items in question are not “dies” is a factual determination.

This court’s- review of the board’s decision is limited to questions of law and “ [i] t is not the function of the court to substitute its judgment for that of the Board of Tax Appeals on factual issues, but only to determine from the record whether the decision rendered by the board is…