United Telephone Co. v. Limbach

Both the commissioner and the BTA found, pursuant to R.C. 5727.06 as amended in 1982, that all of United Telephone’s tangible personal property “owned and located in this state” was subject to personal property tax, including property not “used in business.” The BTA held that amendments resulting from the enactment of Am.Sub.H.B. No. 201, effective December 31, 1982, removed any former requirement that a public utility’s personal property must be “used in business” to be taxable. We reverse.

R.C. 5709.01 establishes' the general principle that all personal property located and “used in…