Simmons v. Cuyahoga County Board of Revision

Simmons contends that the BTA could not fulfill its obligation to determine true value when the BOR did not offer any evidence to justify its valuation. We disagree.

Simmons was the appellant in this matter and therefore the burden was upon him to convince the BTA that his opinion of value was the value that it should accept. In Western Industries, Inc. v. Hamilton Cty. Bd. of Revision (1960), 170 Ohio St. 340, 342, 10 O.O.2d 427, 427, 164 N.E.2d 741, 743, we stated, “The burden is on the taxpayer to prove his right to a deduction. He is not entitled to the deduction claimed merely because no…