Jacob B. Sweeney Equipment Trust v. Limbac

William W. Young, Judge.

Appellant, Jacob B. Sweeney Equipment Trust (“Sweeney”), appeals from the decision of the Ohio Board of Tax Appeals (“BTA”) affirming an order of appellee, Joanne Limbach, Tax Commissioner of Ohio (“Tax Commissioner”), concerning personal property tax assessments for the 1986 tax year. The primary issue for review is whether the Tax Commissioner and the BTA properly determined the true value of a mainframe computer owned by Sweeney and leased to Armco, Inc.

In 1981, Sweeney purchased an IBM Model 3081 computer for the purpose of leasing it to Armco. The purchase price…