French v. Limbach

The sole issue before the court is whether a preliminary *154assessment certificate issued by the Tax Commissioner constitutes a final determination of the Tax Commissioner which can be appealed by a county auditor to the BTA pursuant to R.C. 5717.02. We do not decide the more fundamental questions of whether a county auditor has a right to appeal from any determination of the Tax Commissioner regarding inter-county personal property tax returns, or from any such assessment when it has become final by operation of law, since those issues are not necessary for our determination.

The BTA was created…