Pingue v. Franklin County Board of Revision

I respectfully disagree with the majority’s decision to reverse the Board of Tax Appeals in this case.

The majority believes that the R.C. 5713.03 presumption (that a recent sale price is the best evidence of true value) applies to Pingue’s transaction involving the price that he paid for the purchase of multiple, noncontiguous condominium units, each of which is deemed to be a separate parcel for purposes of real estate taxation. See R.C. 5311.11. The presumption in R.C. 5713.03, however, does not apply to Pingue’s multiple-parcel purchase because the statutory scheme prefers the valuation of…