Equity Dublin Assocs. v. Testa (Slip Opinion)

{¶ 1} This appeal addresses a claim of tax exemption for two separate buildings located on two separate parcels of real property, one of which is situated in the Dublin City School District, the other in the Columbus City School District. The landlords seek the exemption on the basis that Columbus State Community *153College is a tenant in each of the buildings and provides educational services to its students at each location.

{¶ 2} The appellants are the tax commissioner and the boards of education of the two school districts (collectively, the “BOE”). The commissioner and the BOE seek reversal…