CC Leasing Corp. v. Limbach

The two issues presented for review are whether the fuel assemblies must be listed under R.C. 5711.22(C) or (D), and whether the commissioner’s valuation was reasonable. For the reasons set forth below, we must reverse the decision of the Board of Tax Appeals.

I

R.C. 5711.22, as it. applied to tax years 1978-1982, provided:

“(C) Boilers, machinery, equipment, and personal property used for the generation or distribution of electricity other than for the use of the person generating or distributing such electricity shall be listed and assessed as its true value in money on the day that it is…