Columbus Board of Education v. J.C. Penney Properties, Inc.

Appellant argues in its first two propositions of law that it was unreasonable and unlawful for the board to apply a common level of assessment of 31.2 percent in determining the taxable value of Penney’s property.

We agree. The Board of Tax Appeals has no authority to determine the common level of assessment on appeal. The board’s powers upon appeal are enumerated in R.C. 5717.03 which provides, in part:

“In case of an appeal from a decision of a county board of revision, the board of tax appeals shall determine the taxable value of the property whose valuation or assessment by the county…