Church of God in Northern Ohio, Inc. v. Levin

{¶ 34} I believe that the Church of God in Northern Ohio (“COG”) uses its property exclusively for the charitable purposes of providing public worship and community programs and is therefore exempt from taxation under R.C. 5709.12(B). Accordingly, I respectfully dissent.

{¶ 35} Under R.C. 5709.12, property is exempt from taxation if “(1) the property belongs to an institution, and (2) the property is being used exclusively for charitable purposes.” Highland Park Owners, Inc. v. Tracy (1994), 71 Ohio St.3d 405, 406-407, 644 N.E.2d 284. It is undisputed that COG is an institution. The question…