Geneva Area Recreational, Educational & Athletic Trust v. Testa (Slip Opinion)

{¶ 1} In 2009, appellant, the Geneva Area Recreational, Educational and Athletic Trust, a nonprofit corporation under 26 U.S.C. 501(c)(3) d.b.a. Spire Institute (“Spire”), entered into an agreement to lease more than 160 acres of land in Geneva, Ohio, from Roni Lee, L.L.C. (“Roni Lee”), a for-profit company. By 2012, Spire had constructed Olympic-grade athletic facilities and related improvements on about one-fourth of the property. In tax year 2010, Spire sought a real-estate-tax exemption for the entire property under the charitable-use exemption, citing R.C. 5709.12 and 5709.121. The tax…