Rowe-Reilly Corp. v. Tracy

This is an appeal from a decision of the BTA wherein the BTA affirmed assessments by the Tax Commissioner that taxed as personal property certain items of inventory owned by the appellant. The assessments levied against the appellant were for tax years 1988 through 1993.2

During the tax years in question in this matter, R.C. 5709.01(B) provided in pertinent part that unless otherwise expressly exempted from taxation:

“(1) All personal property located and used in business in this state * * * [is] subject to taxation * *

For tax years 1988 to mid-1991, R.C. 5701.08 provided in pertinent part:

“(A)…