Satullo v. Wilkins

{¶ 1} The appellants, S. Sandy Satullo II and Copper Kettle Marina, Inc., argue in this appeal as of right that they do not owe Ohio use tax for their use of two boats between November 1, 1995, and October 31, 1999. The Board of Tax Appeals (“BTA”) found that the state Tax Commissioner had properly imposed a use tax on the appellants. According to the BTA, the appellants did not purchase the boats with the intent to resell them, and therefore the R.C. 5739.01(E) resale exception to the sales and use tax did not apply. The BTA likewise rejected the appellants’ request for a tax exemption under…