Concord Columbus, L.P. v. Testa

Tyack, Presiding Judge.

Concord Columbus, L.P. (“Concord Columbus”) is the owner of certain real property located at 35 West Spring Street, Columbus, Ohio. The property is the site of the Courtyard by Marriott Hotel, which was purchased by Concord Columbus in 1992 for $1,400,000. Following substantial renovations, the hotel ultimately opened for business in April 1994. The dispute before us concerns the valuation, for tax purposes, of the property during the renovation period.

Ohio Adm.Code 5705-3-02(G) sets forth the procedure by which the county auditor is to determine the valuation of a…