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Banbury Village, Inc. v. Cuyahoga County Board of Revision
Citations: 53 Ohio St. 3d 251; 559 N.E.2d 1356; 1990 Ohio LEXIS 1046Docket: No. 89-855
Court: Ohio Supreme Court; September 12, 1990; Ohio; State Supreme Court
The appeal challenges the Board of Tax Appeals' (BTA) valuation of the subject property, claiming it was unreasonable and unlawful due to not reflecting the highest and best use, reliance on actual sales of other properties, and violations of constitutional rights. The court affirms the BTA’s decision, stating it is supported by substantial evidence and is both reasonable and lawful. The BTA's determination of true value, a factual question, will only be overturned if shown to be unreasonable or unlawful. The court emphasizes it will not substitute its judgment for that of the BTA on factual matters. The BTA has discretion in its valuation and is not obligated to adopt expert opinions, as evidenced by the appellant's appraiser's admission that he did not consider sales from other owners and relied solely on income and expenses to derive a lower property value. In contrast, the BTA evaluated multiple sales showing higher prices, indicating arm's-length transactions. The appellant's constitutional arguments regarding uniformity of taxation, due process, and equal protection are dismissed. The BTA's valuation was found compliant with state constitutional requirements and statutory law. The court distinguishes the appellant's case from previous precedents involving due process, finding no arbitrary or excessive assessment. Additionally, there is no evidence supporting the equal protection claim, as the Supreme Court has established that states are not required to maintain precise uniformity in taxation. Consequently, the court affirms the BTA's decision, finding no violations of constitutional rights.