Citizens Financial Corp. v. Porterfield

The appellant’s first contention is that the decision of the Board of Tax Appeals is unreasonable and unlawful because the appellant’s business activities as of the tax listing day, December 31, 1964 (R. C. 5725.14), did not constitute it a dealer in intangibles within the meaning of paragraph (B) of R. C. 5725.01.3 Upon an examina*56tion of the record, which reveals that Citizens Financial extended loans to its clients and that it served in the capacity of an agent in seeking adequate financing for its clients, we conclude that the appellant was a dealer in intangibles within the meaning of…