One Columbus Buldg. v. Div. of Income Tax, Unpublished Decision (11-30-1999)

OPINION

One Columbus Building Associates Ltd., plaintiff-appellant, appeals a decision of the Franklin County Court of Common Pleas. The trial court granted a motion for summary judgment filed by The City of Columbus, Division of Income Tax, defendant-appellee. We reverse and remand.

Appellant was an Ohio limited partnership that owned and operated an office building on West Broad Street in Columbus, Ohio. On November 12, 1993, appellant sold the building for $50,000,000. In its 1993 federal income tax return, appellant claimed that it had incurred costs for the property of $49,287,292.…