Summer Rays, Inc. v. Testa

{¶ 1} Appellant, Summer Rays, Inc. ("Summer Rays"), appeals from a decision of the Ohio Board of Tax Appeals ("BTA") affirming the final determination of appellee, Joseph W. Testa, Tax Commissioner of Ohio ("commissioner"), denying Summer Rays' request for property tax exemption pursuant to R.C. 5709.12. For the following reasons, we affirm.

I. Factual and Procedural Background

{¶ 2} Summer Rays is an Ohio not-for-profit corporation with Internal Revenue Code 501(c)(3) status, and Chuck Kirk is the corporation's president and executive director. Summer Rays provides "Christian Access Living…