Board of Education v. Board of Revision

Appellants first argue that the BTA should have considered the sale of the property in 1985 in arriving at its valuation. Appellants’ failure to support their motion for reconsideration with an affidavit was contrary to the BTA’s rule, Ohio Adm. Code 5717-1-07(B).1 The BTA may adopt rules to govern proceedings before it. R.C. 5703.02(D). Unless it is unreasonable or in conflict with statute, a rule has the effect of law. Kroger Grocery & Baking Co. v. Glander (1948), 149 Ohio St. 120, 125, 36 O.O. 471, 474, 77 N.E. 2d 921, 924. The BTA’s failure to consider evidence *319of this sale was neither…