Background
Main and Nelson Station LLC sought a reduction in the value of property in Dublin, Ohio. The Franklin County Board of Revision issued a no-value-change decision, and the owner appealed to the Ohio Board of Tax Appeals. The Dublin City Schools Board of Education moved to dismiss before the BTA, arguing that the BOR lacked jurisdiction over the valuation matter.
On September 4, 2025, the BTA vacated the BOR’s decision and remanded with instructions to dismiss. The BTA’s decision contained an incomplete sentence. At the owner’s request, the BTA issued a September 30 order completing that sentence. The owner filed notices of appeal with the court of appeals, but did not successfully file a notice of appeal with the BTA until October 11.
The Court’s Holding
The Tenth District dismissed both appeals for lack of jurisdiction. Under R.C. 5717.04, an appeal from a BTA decision must be filed with both the court of appeals and the BTA within 30 days, and those requirements are mandatory and jurisdictional.
The September 30 order was effectively a nunc pro tunc order correcting a clerical omission, not a new substantive decision. It therefore related back to the September 4 BTA decision and did not restart the appeal period. The filing deadline was October 6, 2025, but the owner did not file its notice with the BTA until October 11 and did not establish an officially acknowledged system outage that could excuse the delay.
Key Takeaways
- A BTA appeal requires timely filing with both the appellate court and the BTA.
- A clerical nunc pro tunc correction does not extend the deadline to appeal the original decision.
- An alleged electronic-filing problem does not establish timeliness without the showing required for a BTA system outage.
Why It Matters
The decision underscores the strict jurisdictional consequences of missing the dual-filing deadline in Ohio property-tax appeals. Parties should verify that a notice of appeal has actually been filed and docketed with each required tribunal rather than relying on an attempted electronic submission.