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Cobblestone Square Co. v. Lorain County Board of Revision

Citation: 106 Ohio St. 3d 305Docket: No. 2004-0883

Court: Ohio Supreme Court; October 12, 2005; Ohio; State Supreme Court

Narrative Opinion Summary

The case involves a dispute over the valuation of a property purchased by Cobblestone Square Co. Ltd., which included a former Kmart building, for tax purposes. The Lorain County Auditor initially valued the property at $3,417,110, but the Elyria City School District's Board of Education argued for a valuation equivalent to the purchase price of $5,800,000. Cobblestone contested this, supporting the auditor's valuation. After a series of appeals and remands, the Board of Tax Appeals (BTA) affirmed a property value of $5,800,000. Cobblestone argued that the purchase was conducted under economic duress, drawing parallels to a precedent of non-arm's-length transactions. However, the court found no substantial evidence of duress, noting that the transaction was a strategic business decision rather than a coerced action. Cobblestone's assumption of the Kmart lease and subsequent purchase were deemed voluntary, with no significant lease term changes or market exposure issues identified. The BTA's decision was upheld as reasonable and lawful, confirming the property's valuation at the purchase price.

Legal Issues Addressed

Arm's-Length Transaction

Application: The court evaluated whether the sale of the property was voluntary and at arm's length, ultimately finding no evidence of economic duress.

Reasoning: Cobblestone argues that the Board of Tax Appeals (BTA) incorrectly determined that its purchase of the Kmart property was not driven by economic duress.

Economic Duress in Real Estate Transactions

Application: The court found insufficient evidence of economic duress affecting Cobblestone's purchase of the property, rejecting claims of non-negotiable offers and insolvency threats.

Reasoning: Cobblestone's case lacks evidence of true economic duress; while it asserts that offers were non-negotiable, there is no proof that the property was not exposed to the market.

Property Valuation for Tax Purposes

Application: The Board of Tax Appeals determined the property's value based on the purchase price despite arguments to the contrary.

Reasoning: The BTA ultimately determined the value to be $5,800,000, which is affirmed by the court.