Stag Indus. Holdings, L.L.C. v. Cuyahoga Cty. Bd. of Revision

Citations

• 2024 Ohio 2814

Syllabus

Tax real property value board of revision board of tax appeals arm's-length sale market value increase allocation land improvements land value building value fiscal officer auditor independent judgment reasonable and lawful burden record lack of evidence support reversed remanded modify. Reversed and remanded decision of the Board of Tax Appeals (\BTA\) to affirm the Cuyahoga County Board of Revision's (\BOR's\) allocation of a property's total value between land and improvements for the relevant tax year. The BTA's decision regarding the allocation was unreasonable and unlawful when there was no evidence in the record to support the BOR's increase in the land value or from which the BTA could independently determine a land value other than the value set by the fiscal officer or county auditor. The matter was remanded with instructions to modify the allocation.