Wallover Oil Co. v. Ohio Water Pollution Control Board

0’Neill, C. J.

A statute which purports to grant a tax exemption is strictly construed. An applicant seeking such exemption must affirmatively establish his right thereto. National Tube Co. v. Glander (1952), 157 Ohio St. 407. The court does not indulge in presumptions favoring a tax exemption. Goldman v. Bentley Post (1952), 158 Ohio St. 205, 207. A party seeking exemption has the burden of demonstrating that he meets the statutory qualifications for tax exemption.

R. C. 6111.31 provides:

“Appliances, equipment, machinery, and structures comprising all or a part of an industrial water pollution…