Ohio Bell Telephone Co. v. Levin

{¶ 1} The Tax Commissioner contends that the Board of Tax Appeals (“BTA”) lacked jurisdiction to reduce his valuation of certain personal property of The Ohio Bell Telephone Company (“Ohio Bell”). In modifying the commissioner’s valuation, the BTA relied on a theory of error that was not specified in Ohio Bell’s notice of appeal to the BTA. Therefore, we agree that the BTA lacked jurisdiction, and we reverse the decision of the BTA and reinstate the determination of the commissioner.

I

{¶ 2} Pursuant to statute, public utilities must pay property tax. The property tax is an ad valorem tax; the…