Federated Department Stores, Inc. v. Lindley

The primary focus throughout this appeal has been on whether the tax assessment predicated on “Account 215” was valid. For the *215following reasons, this court holds that the board’s decision, that the assessment based on this account was invalid, was neither unlawful nor unreasonable.

Rike’s has argued that Account 215 was only an estimate of sales tax liability and thus could not be used as the basis of an assessment. Contrastingly, the commissioner has argued that R.C. 5739.13 authorizes an assessment upon “any information” that a vendor is not remitting to the state all of the sales tax that…