On appeal of County Board of Revision’s (“BOR”) valuation before the Board of Tax Appeals (“BTA”), Lowe’s and the county presented competing property appraisals. The BTA adopted the county’s appraisal, and Lowe’s appealed.
Lowe’s argued that the BTA adopted the county’s appraisal without addressing whether the evidence justified applying the special-purpose doctrine that was the basis for the Ohio Supreme Court’s holding in Meijer Stores.
The Supreme Court of Ohio held that the BTA’s adoption of the county’s appraisal without addressing whether the evidence justified applying the special-purpose doctrine required vacation of the BTA’s decision and remand for further proceedings.
Leased comparables will typically need to be adjusted in determining the value of a subject property that is itself unencumbered by such a lease; however, adjustments may not be necessary when the special-purpose doctrine applies.