International Business MacHines Corp. v. Levin

{¶ 1} Appellants, International Business Machines Corporation (“IBM Corp.”) and IBM Credit Corporation (“IBM Credit”) (collectively, “IBM”), appeal from a decision of the Board of Tax Appeals (“BTA”) that affirmed three final determinations of the Tax Commissioner, each of which declined to award interest on certain refunds. We hold that the commissioner and the BTA properly denied the interest claims.

Facts

{¶ 2} The factual record in this case is sparse, and there are no evidentiary disputes. Citing R.C. 5739.071 and 5741.10 as the statutory bases, the Tax Commissioner issued separate final…