Gahanna-Jefferson Public Schools Board of Education v. Franklin County Board of Revision

These cases were consolidated for hearing and sua sponte are consolidated for decision.

The essence of the BOE’s appeal in both cases is that the transactions in question should be considered as a sale of real property for valuation purposes. We disagree.

We must first determine what was sold by Wren and Newkam or the partners thereof and purchased by Associated. There is no evidence in either of these cases that either partnership sold real property to Associated separate from the *453partnership interests. If the partnership, as distinguished from the partners, sold real property to Associated,…