Management Horizons, Inc. v. Lindley

B. C. 5709.01 subjects to taxation “[a]ll personal property located and used in business in this state * * * regardless of the residence of the owners thereof.”

Management Horizons, Inc., maintains that it was a holding company; that it was not using property in business in Ohio because it was not doing business in Ohio; and, therefore, that it is not subject to the Ohio personal property tax on its account receivable from MHDS.

The Board of Tax Appeals concluded that there was active participation by the appellant in the business of its subsidiary, MHDS, and it was, therefore, engaged in…