HB 590: Modify law governing tax appeals and property tax complaints
This bill aims to modify the law governing tax appeals and property tax complaints in Ohio. A complaint can be filed with the county auditor on or before the 31st day of March or the date of the collection for the first half of real and public utility property taxes for the current tax year. The complaint can be filed by a property owner, their spouse, a tenant, or a person acting on behalf of a property owner, such as a public accountant or a real estate appraiser. The complaint can be filed regarding various determinations, including classification, valuation, and assessment of parcels. A person cannot file a complaint against the valuation or assessment of a parcel if they previously filed a complaint for the same parcel in the same interim period, unless they can demonstrate a change in circumstances, such as a sale in an arm's length transaction or a decrease in property value. The…
| Nov. 19, 2025 | Referred to committee: Ways and Means |
| Nov. 12, 2025 | Introduced |
As Introduced
136th General Assembly
Regular Session
H. B. No. 590
2025-2026
Representatives Thomas, D., Williams
Cosponsors: Representatives Newman, Ritter
To amend sections 5715.19 and 5717.04 of the 1
Revised Code to modify the law governing tax
appeals and property tax complaints.
BE IT ENACTED BY THE GENERAL ASSEMBLY OF THE STATE OF OHIO:
Section 1. That sections 5715.19 and 5717.04 of the 4
Revised Code be amended to read as follows:
Sec. 5715.19. (A) As used in this section:
"Member" has the same meaning as in section 1706.01 of the 7
Revised Code.
"Internet identifier of record" has the same meaning as in 9
section 9.312 of the Revised Code.
"Interim period" means, for each county, the tax year to 11
which section 5715.24 of the Revised Code applies and each 12
subsequent tax year until the tax year in which that section 13
applies again.
"Legislative authority" means a board of county 15
commissioners, a board of township trustees of any township with 16
territory in the county, the board of education of any school 17
district with territory in the county, or the legislative 18
Authority of a municipal corporation with territory in the 19
County.
"Original complaint" means a complaint filed under division (A) of this section.
"Counter-complaint" means a complaint filed under division (B) of this section in response to an original complaint.
"Third party complainant" means a complainant other than the property owner, the owner's spouse, a tenant authorized to file an original complaint, or any person acting on behalf of a property owner. "Third party complainant" does not include a legislative authority or a mayor of a municipal corporation, but does include the prosecuting attorney or treasurer of a county or any person acting on behalf of a legislative authority or mayor.
For purposes of this section, a person is considered to be acting on behalf of a legislative authority or mayor if the person is an official or employee of the political subdivision or has been hired, contracted, or directed by such an official or employee to file a complaint or counter-complaint under this section on behalf of the political subdivision.
(1) Subject to division (A) (2) of this section, a complaint against any of the following determinations for the current tax year shall be filed with the county auditor on or before the thirty-first day of March of the ensuing tax year or the date of closing of the collection for the first half of real and public utility property taxes for the current tax year, whichever is later:
(a) Any classification made under section 5713.041 of the Revised Code;
(b) Any determination made under section 5713.32 or 48 5713.35 of the Revised Code;
(c) Any recoupment charge levied under section 5713.35 of 50 the Revised Code;
(d) The determination of the total valuation or assessment 52 of any parcel that appears on the tax list, except parcels 53 assessed by the tax commissioner pursuant to section 5727.06 of 54 the Revised Code;
(e) The determination of the total valuation of any parcel 56 that appears on the agricultural land tax list, except parcels 57 assessed by the tax commissioner pursuant to section 5727.06 of 58 the Revised Code;
(f) Any determination made under division (A) of section 60 319.302 of the Revised Code.
If such a complaint is filed by mail or certified mail, 62 the date of the United States postmark placed on the envelope or 63 sender's receipt by the postal service shall be treated as the 64 date of filing. A private meter postmark on an envelope is not a 65 valid postmark for purposes of establishing whether a complaint 66 has been timely filed.
Subject to division (A) (6) of this section, any person 68 owning taxable real property in the county or in a taxing 69 district with territory in the county; such a person's spouse; a 70 tenant of the property owner, if the property is classified as 71 to use for tax purposes as commercial or industrial, the lease 72 requires the tenant to pay the entire amount of taxes charged 73 against the property, and the lease allows, or the property 74 owner otherwise authorizes, the tenant to file such a complaint 75 with respect to the property; an individual who is retained by 76 such a person or tenant and who holds a designation from a professional assessment organization, such as the institute for professionals in taxation, the national council of property taxation, or the international association of assessing officers; a public accountant who holds a permit under section 4701.10 of the Revised Code, a general or residential real estate appraiser licensed or certified under Chapter 4763. of the Revised Code, or a real estate broker licensed under Chapter 4735. of the Revised Code, who is retained by such a person or tenant; if the person or tenant is a firm, company, association, partnership, limited liability company, or corporation, an officer, a salaried employee, a partner, or a member of that person or tenant; if the person or tenant is a trust, a trustee of the trust; the prosecuting attorney or treasurer of the county; or the legislative authority of a subdivision or the mayor of a municipal corporation may file such a complaint regarding any such determination affecting any real property in the county, except that a person owning taxable real property in another county may file such a complaint only with regard to any such determination affecting real property in the county that is located in the same taxing district as that person's real property is located. The county auditor shall present to the county board of revision all complaints filed with the auditor.
(2) No person, legislative authority, or officer shall file a complaint against the valuation or assessment of any parcel that appears on the tax list if it filed a complaint against the valuation or assessment of that parcel for any prior tax year in the same interim period, unless the person, legislative authority, or officer alleges that the valuation or assessment should be changed due to one or more of the following circumstances that occurred after the tax lien date for the tax year for which the prior complaint was filed and that the circumstances were not taken into consideration with respect to the prior complaint:
(a) The property was sold in an arm's length transaction, 111 as described in section 5713.03 of the Revised Code;
(b) The property lost value due to some casualty; 113
(c) Substantial improvement was added to the property; 114
(d) An increase or decrease of at least fifteen per cent 115 in the property's occupancy has had a substantial economic 116 impact on the property.
(3) If a county board of revision, the board of tax 118 appeals, or any court dismisses a complaint filed under this 119 section or section 5715.13 of the Revised Code for the reason 120 that the act of filing the complaint was the unauthorized 121 practice of law or the person filing the complaint was engaged 122 in the unauthorized practice of law, the party affected by a 123 decrease in valuation or the party's agent, or the person owning 124 taxable real property in the county or in a taxing district with 125 territory in the county, may refile the complaint, 126 notwithstanding division (A) (2) of this section.
(4) (a) No complaint filed under this section or section 128 5715.13 of the Revised Code shall be dismissed for the reason 129 that the complaint fails to accurately identify the owner of the 130 property that is the subject of the complaint.
(b) If a complaint fails to accurately identify the owner 132 of the property that is the subject of the complaint, the board 133 of revision shall exercise due diligence to ensure the correct 134 property owner is notified as required by divisions (B) and (C) 135 of this section.
(5) Notwithstanding division (A) (2) of this section, a 137 person, legislative authority, or officer may file a complaint 138 against the valuation or assessment of any parcel that appears 139 on the tax list if it filed a complaint against the valuation or 140 assessment of that parcel for any prior tax year in the same 141 interim period if the person, legislative authority, or officer 142 withdrew the complaint before the complaint was heard by the 143 board.
(6) The legislative authority of a subdivision, the mayor 145 of a municipal corporation, or a third party complainant shall 146 not file an original complaint with respect to property the 147 subdivision or complainant does not own or lease unless both of 148 the following conditions are met:
(a) If the complaint is based on a determination described 150 in division (A) (1) (d) or (e) of this section, all of the 151 following requirements are met:
(i) The complaint seeks an increase in the valuation of 153 the property based upon the sale of the property in an arm's 154 length transaction, as described in section 5713.03 of the 155 Revised Code.
(ii) Either of the following conditions apply to that sale 157 during the two years preceding the tax lien date for the tax 158 year for which the complaint is to be filed:
(I) The sale is evidenced by a conveyance fee statement, 160 attached to the complaint, that declares the value of the 161 property conveyed pursuant to section 319.202 of the Revised 162 Code and that was filed during those two years.
(II) The sale is otherwise recorded in the office of the 164 county recorder or similar government office during those two 165 years.
(iii) That sale price exceeds the true value of the property appearing on the tax list for that tax year by both ten per cent and the amount of the filing threshold determined under division (J) of this section.
(b) If the complaint is filed by a legislative authority, mayor, or third party complainant acting on behalf of a legislative authority or mayor, the legislative authority or, in the case of a mayor, the legislative authority of the municipal corporation, first adopts a resolution authorizing the filing of the original complaint at a public meeting of the legislative authority.
(7) A resolution adopted under division (A) (6) (b) of this section shall include all of the following information:
(a) Identification of the parcel or parcels that are the subject of the original complaint by street address, if available from online records of the county auditor, and by permanent parcel number;
(b) The name of at least one of the record owners of the parcel or parcels;
(c) The basis for the complaint under divisions (A) (1) (a) to (f) of this section relative to each parcel identified in the resolution;
(d) The tax year for which the complaint will be filed, which shall be a year for which a complaint may be timely filed under this section at the time of the resolution's adoption.
A legislative authority shall not adopt a resolution required under division (A) (6) (b) of this section that identifies more than one parcel under division (A) (7) (a) of this section, except that a single resolution may identify more than one parcel under that division if each parcel has the same record owner or the same record owners, as applicable. A legislative authority may adopt multiple resolutions required under division (A) (6) (b) of this section by a single vote, provided that the vote is separate from the question of whether to adopt any resolution that is not adopted under division (A) (6) (b) of this section.
Before adopting a resolution required by division (A) (6) (b) of this section, the legislative authority shall mail a written notice to at least one of the record owners of the parcel or parcels identified in the resolution stating the intent of the legislative authority in adopting the resolution, the proposed date of adoption, and the basis for the complaint under divisions (A) (1) (a) to (f) of this section relative to each parcel identified in the resolution. The notice shall be sent by certified mail to the last known tax-mailing address of at least one of the record owners and, if different from that tax-mailing address, to the street address of the parcel or parcels identified in the resolution. Alternatively, if the legislative authority has record of an internet identifier of record associated with at least one of the record owners, the legislative authority may send the notice by ordinary mail and by that internet identifier of record. The notice shall be postmarked or, if sent by internet identifier of record, sent at least seven calendar days before the legislative authority adopts the resolution.
A board of revision has jurisdiction to consider a complaint filed pursuant to a resolution adopted under division (A) (6) (b) of this section only if the legislative authority notifies the board of revision of the resolution in the manner prescribed in division (A) (8) (a) of this section. The failure to accurately identify the street address or the name of the record owners of the parcel in the resolution does not invalidate the resolution nor is it a cause for dismissal of the complaint.
(8) (a) A complaint form prescribed by a board of revision or the tax commissioner for the purpose of this section shall include a box that must be checked, when a legislative authority, mayor, or third party complainant acting on behalf of either files an original complaint, to indicate that a resolution authorizing the complaint was adopted in accordance with divisions (A) (6) (b) and (7) of this section and that notice was mailed or sent in accordance with division (A) (7) of this section before adoption of the resolution to at least one of the record owners of the property that is the subject of the complaint.
(b) Any third party complainant shall submit, with the complaint, a sworn affidavit stating whether the third party complainant is or is not acting on behalf of a legislative authority or mayor.
(B) (1) Within thirty days after the last date such complaints may be filed, the auditor shall give notice of each complaint in which the stated amount of overvaluation, undervaluation, discriminatory valuation, illegal valuation, or incorrect determination is at least seventeen thousand five hundred dollars in taxable value to each property owner whose property is the subject of the complaint, if the complaint was not filed by the owner or the owner's spouse. A board of education, subject to this division; a property owner; the owner's spouse; a tenant of the owner, if that tenant would be eligible to file a complaint under division (A) of this section with respect to the property; an individual who is retained by such an owner or tenant and who holds a designation from a professional assessment organization, such as the institute for professionals in taxation, the national council of property taxation, or the international association of assessing officers; a public accountant who holds a permit under section 4701.10 of the Revised Code, a general or residential real estate appraiser licensed or certified under Chapter 4763. of the Revised Code, or a real estate broker licensed under Chapter 4735. of the Revised Code, who is retained by such an owner or tenant; or, if the owner or tenant is a firm, company, association, partnership, limited liability company, corporation, or trust, an officer, a salaried employee, a partner, a member, or trustee of that owner or tenant, may file a counter-complaint in support of or objecting to the amount of alleged overvaluation, undervaluation, discriminatory valuation, illegal valuation, or incorrect determination stated in a previously filed original complaint or objecting to the current valuation.
(2) A board of education may file a counter-complaint only 275 if the original complaint (a) was filed by the owner of the 276 property that is the subject of the complaint, a tenant of that 277 property owner, or any person acting on behalf of such owner or 278 tenant, and (b) states an amount of overvaluation, 279 undervaluation, discriminatory valuation, illegal valuation, or 280 incorrect determination of at least seventeen thousand five 281 hundred dollars in taxable value.
The board shall file the counter-complaint within thirty 283 days after the original complaint is filed or after the last day 284 such complaints may be filed, whichever is later, and any other 285 person shall file the counter-complaint within thirty days after 286 receiving the notice required under this division.
(3) Upon the filing of a counter-complaint, the board of 288 education, property owner, or tenant shall be made a party to 289 the action.
(C) Each board of revision shall notify any complainant 291 and counter-complainant, and also the property owner, if the 292 property owner's address is known, and the complaint is filed by 293 one other than the property owner, not less than ten days prior 294 to the hearing, either by certified mail or, if the board has 295 record of an internet identifier of record associated with the 296 owner, by ordinary mail and by that internet identifier of 297 record of the time and place the same will be heard. The board 298 of revision shall hear and render its decision on an original 299 complaint within one hundred eighty days after the last day such 300 a complaint may be filed with the board under division (A) (1) of 301 this section or, if a counter-complaint is filed, within one 302 hundred eighty days after such filing. If the original complaint 303 is filed by the legislative authority of a subdivision, the 304 mayor of a municipal corporation with territory in the county, 305 or a third party complainant, and if the board of revision has 306 not rendered its decision on the complaint within one year after 307 the date the complaint was filed, the board may dismiss the 308 complaint.
(D) The determination of any such original complaint or 310 counter-complaint shall relate back to the date when the lien 311 for taxes or recoupment charges for the current year attached or 312 the date as of which liability for such year was determined. 313 Liability for taxes and recoupment charges for such year and 314 each succeeding year until the complaint is finally determined 315 and for any penalty and interest for nonpayment thereof within 316 the time required by law shall be based upon the determination, 317 valuation, or assessment as finally determined. Each complaint 318 shall state the amount of overvaluation, undervaluation, 319 discriminatory valuation, illegal valuation, or incorrect 320 classification or determination upon which the complaint is 321 based. The treasurer shall accept any amount tendered as taxes 322 or recoupment charge upon property concerning which a complaint 323 is then pending, computed upon the claimed valuation as set 324 forth in the complaint. Unless dismissal is required under 325 division (C) of this section, if an original complaint or 326 counter-complaint filed for the current year is not determined 327 by the board within the time prescribed for such determination, 328 the complaint and any proceedings in relation thereto shall be 329 continued by the board as a valid complaint for any ensuing year 330 until that original complaint or counter-complaint is finally 331 determined by the board or upon any appeal from a decision of 332 the board. In such case, the original complaint and counter- 333 complaint shall continue in effect without further filing by the 334 original taxpayer, the original taxpayer's assignee, or any 335 other person or entity authorized to file a complaint under this 336 section.
(E) If a taxpayer files a complaint as to the 338 classification, valuation, assessment, or any determination 339 affecting the taxpayer's own property and tenders less than the 340 full amount of taxes or recoupment charges as finally 341 determined, an interest charge shall accrue as follows:
(1) If the amount finally determined is less than the 343 amount billed but more than the amount tendered, the taxpayer 344 shall pay interest at the rate per annum prescribed by section 345 5703.47 of the Revised Code, computed from the date that the 346 taxes were due on the difference between the amount finally 347 determined and the amount tendered. This interest charge shall 348 be in lieu of any penalty or interest charge under section 349 323.121 of the Revised Code unless the taxpayer failed to file a 350 complaint and tender an amount as taxes or recoupment charges 351 within the time required by this section, in which case section 352 323.121 of the Revised Code applies.
(2) If the amount of taxes finally determined is equal to 354 or greater than the amount billed and more than the amount 355 tendered, the taxpayer shall pay interest at the rate prescribed 356 by section 5703.47 of the Revised Code from the date the taxes 357 were due on the difference between the amount finally determined 358 and the amount tendered, such interest to be in lieu of any 359 interest charge but in addition to any penalty prescribed by 360 section 323.121 of the Revised Code.
(F) Upon request of a complainant, the tax commissioner 362 shall determine the common level of assessment of real property 363 in the county for the year stated in the request that is not 364 valued under section 5713.31 of the Revised Code, which common 365 level of assessment shall be expressed as a percentage of true 366 value and the common level of assessment of lands valued under 367 such section, which common level of assessment shall also be 368 expressed as a percentage of the current agricultural use value 369 of such lands. Such determination shall be made on the basis of 370 the most recent available sales ratio studies of the 371 commissioner and such other factual data as the commissioner 372 deems pertinent.
(G) A-(G)(1) Except as otherwise provided in division (G) 374 (1) of this section, a complainant shall provide to the board of 375 revision all information or evidence within the complainant's 376 knowledge or possession that affects the real property that is 377 the subject of the complaint. In the case described in division 378 (G) (2) of this section, a complainant may provide such 379 information or evidence. A complainant who fails to provide such 380 information or evidence is precluded from introducing it on 381 appeal to the board of tax appeals or the court of common pleas, 382 except that the board of tax appeals or court may admit and 383 consider the evidence if the complainant shows good cause for 384 the complainant's failure to provide the information or evidence 385 to the board of revision.
(2) If a property owner, the owner's spouse, a tenant 387 authorized to file a complaint under division (A) of this 388 section, or any person acting on behalf of the property owner or 389 tenant files a complaint under division (A) (1) (d) or (e) of this 390 section, the county auditor shall provide to the board of 391 revision all information or evidence within the auditor's 392 knowledge or possession that affects the valuation of the real 393 property that is the subject of the complaint. An auditor who 394 fails to provide such information or evidence is precluded from 395 introducing it on appeal to the board of tax appeals or the 396 court of common pleas, except that the board of tax appeals or 397 court may admit and consider the evidence if the auditor shows 398 good cause for the auditor's failure to provide the information 399 or evidence to the board of revision.
For a complaint filed under division (A) (1) (d) or (e) of 401 this section, the county auditor has the burden of establishing 402 by a preponderance of the evidence that the valuation of the 403 real property that is the subject of the complaint is not an 404 overvaluation, undervaluation, discriminatory valuation, or 405 illegal valuation of that property, as applicable to the 406 complaint.
(H) In case of the pendency of any proceeding in court408 based upon an alleged excessive, discriminatory, or illegal 409 valuation or incorrect classification or determination, the 410 taxpayer may tender to the treasurer an amount as taxes upon 411 property computed upon the claimed valuation as set forth in the 412 complaint to the court. The treasurer may accept the tender. If 413 the tender is not accepted, no penalty shall be assessed because 414 of the nonpayment of the full taxes assessed.
(I) A legislative authority, or any person acting on 416 behalf of a legislative authority, may not enter into a private 417 payment agreement with respect to any complaint filed or 418 contemplated under this section or section 5715.13 of the 419 Revised Code, and any such agreement is void and unenforceable. 420 As used in this division, "private payment agreement" means any 421 type of agreement in which a property owner, a tenant authorized 422 to file a complaint under division (A) of this section, or any 423 person acting on behalf of a property owner or such a tenant 424 agrees to make one or more payments to a subdivision in exchange 425 for the legislative authority of that subdivision, or any person 426 acting on behalf of that subdivision, doing any of the 427 following:
(1) Refraining from filing a complaint or counter- 429 complaint under this section;
(2) Dismissing a complaint or counter-complaint filed 431 under this section by the legislative authority or any person 432 acting on behalf of the legislative authority;
(3) Resolving a claim under this section by settlement 434 agreement.
A "private payment agreement" does not include any 436 agreement to resolve a claim under this section pursuant to 437 which an agreed-upon valuation for the property that is the 438 subject of the claim is approved by the county auditor and 439 reflected on the tax list, provided that agreement does not 440 require any payments described in this division.
(J) For the purpose of division (A) (6) (a) of this section, 442 the filing threshold for tax year 2022 equals five hundred 443 thousand dollars. For tax year 2023 and each tax year 444 thereafter, the tax commissioner shall adjust the filing 445 threshold used in that division by completing the following 446 calculations in September of each year:
(1) Determine the percentage increase in the gross 448 domestic product deflator determined by the bureau of economic 449 analysis of the United States department of commerce from the 450 first day of January of the preceding year to the last day of 451 December of the preceding year;
(2) Multiply that percentage increase by the filing 453 threshold for the current year;
(3) Add the resulting product to the filing threshold for 455 the current year;
(4) Round the resulting sum to the nearest multiple of one 457 thousand dollars.
The commissioner shall certify the amount resulting from 459 the adjustment to each county auditor not later than the first 460 day of October each year. The certified amount applies to 461 complaints filed for the tax year in which the amount is 462 certified. The commissioner shall not make the adjustment for 463 any tax year in which the amount resulting from the adjustment 464 would be less than the filing threshold for the current tax 465 year.
(K) Any person who knowingly makes a false statement in an 467 affidavit furnished under division (A) (8) (b) of this section is 468 guilty of falsification under division (A) (11) of section 469 2921.13 of the Revised Code.
(L) Any property owner or tenant filing a complaint under 471 this section or section 5715.13 of the Revised Code against the 472 valuation of any parcel that appears on the tax list, a counter- 473 complaint to such a complaint, or an appeal of any decision 474 rendered upon such a complaint or counter-complaint under 475 section 5717.01 or 5717.05 of the Revised Code may submit to the 476 board of revision, board of tax appeals, or court of common 477 pleas evidence of similarly situated properties that, the person 478 alleges, establish that the property is overvalued in comparison 479 to its peers, neighbors, or competitive set. If the board or 480 court determines that the evidence is sufficiently credible and 481 the valuations of the similarly situated properties were 482 determined using generally recognized appraisal techniques, the 483 board or court may use the evidence as a basis for a reduction 484 in the property's valuation or, in the case of a counter- 485 complaint, to determine a valuation lesser than that alleged in 486 the complaint. The board or court maintains discretion in 487 determining which properties qualify as similarly situated 488 properties.
Sec. 5717.04. This section does not apply to any decision 490 and order of the board of tax appeals made pursuant to section 491 5703.021 of the Revised Code. Any such decision and order shall 492 be conclusive upon all parties and may not be appealed. 493 The proceeding to obtain a reversal, vacation, or 494 modification of a decision of the board of tax appeals 495 determining appeals from final determinations by the tax- 496 commissioner of any preliminary, amended, or final tax- 497 assessments, reassessments, valuations, determinations, 498 findings, computations, or orders made by the commissioner, and- 499 final determinations of a local board of tax review created- 500 under section 718.11 of the Revised Code, shall be by appeal to 501 the supreme court or to the court of appeals for the county in 502 which the property taxed is situated or in which the taxpayer 503 resides. If the taxpayer is a corporation, then the proceeding 504 to obtain such reversal, vacation, or modification shall be by 505 appeal to the supreme court or to the court of appeals for the 506 county in which the property taxed is situated, or the county of 507 residence of the agent for service of process, tax notices, or 508 demands, or the county in which the corporation has its 509 principal place of business. In all other instances, the 510 proceeding to obtain such reversal, vacation, or modification 511 shall be by appeal to the court of appeals for Franklin county. 512 Appeals from decisions of the board upon all other appeals 513 or applications filed with and determined by the board shall be- 514 by appeal to the court of appeals for the county in which the- 515 property taxed is situated or in which the taxpayer resides. If- 516 the taxpayer is a corporation, limited liability company, 517 partnership, or other legal entity, then the proceeding to- 518 obtain such reversal, vacation, or modification shall be by- 519 appeal to the court of appeals for the county in which the- 520 property taxed is situated, or the county of residence of the- 521 agent for service of process, tax notices, or demands, or the- 522 county in which the corporation, limited liability company, 523 partnership, or other legal entity has its principal place of- 524 business. In all other instances, the proceeding to obtain such- 525 reversal, vacation, or modification shall be by appeal to the- 526 court of appeals for Franklin county.
Appeals from decisions of the board determining appeals 528 from decisions of county boards of revision may be instituted by 529 any of the persons who were parties to the appeal before the 530 board of tax appeals, by the person in whose name the property involved in the appeal is listed or sought to be listed, if such person was not a party to the appeal before the board of tax appeals, or by the county auditor of the county in which the property involved in the appeal is located.
Appeals from decisions of the board of tax appeals determining appeals from final determinations by the tax commissioner of any preliminary, amended, or final tax assessments, reassessments, valuations, determinations, findings, computations, or orders made by the commissioner may be instituted by any of the persons who were parties to the appeal or application before the board, by the person in whose name the property is listed or sought to be listed, if the decision appealed from determines the valuation or liability of property for taxation and if any such person was not a party to the appeal or application before the board, by the taxpayer or any other person to whom the decision of the board appealed from was by law required to be sent, by the director of budget and management if the revenue affected by the decision of the board appealed from would accrue primarily to the state treasury, by the county auditor of the county to the undivided general tax funds of which the revenues affected by the decision of the board appealed from would primarily accrue, or by the tax commissioner.
Appeals from decisions of the board upon all other appeals or applications filed with and determined by the board may be
instituted by any of the persons who were parties to such appeal 557 or application before the board, by any persons to whom the 558 decision of the board appealed from was by law required to be 559 sent, or by any other person to whom the board sent the decision 560 appealed from, as authorized by section 5717.03 of the Revised 561 Code.
Such appeals shall be taken within thirty days after the 563 date of the entry of the decision of the board on the journal of 564 its proceedings, as provided by such section, by the filing by 565 appellant of a notice of appeal with the court to which the 566 appeal is taken and the board. If the appeal is of a decision of 567 the board on an action originally brought under section 5717.01 568 of the Revised Code, the appellant also shall submit, at the 569 same time, a copy of the notice of appeal to the county board of 570 revision and the county auditor. If a timely notice of appeal is 571 filed by a party, any other party may file a notice of appeal 572 within ten days of the date on which the first notice of appeal 573 was filed or within the time otherwise prescribed in this 574 section, whichever is later. A notice of appeal shall set forth 575 the decision of the board appealed from and the errors therein 576 complained of. Proof of the filing of such notice with the board 577 of tax appeals shall be filed with the court to which the appeal 578 is being taken.
The court in which notice of appeal is first filed shall 580 have exclusive jurisdiction of the appeal.
In all such appeals the commissioner or all persons to 582 whom the decision of the board appealed from is required by such 583 section to be sent, other than the appellant, shall be made 584 appellees. Unless waived, notice of the appeal shall be served 585 upon all appellees by certified mail. The prosecuting attorney 586 shall represent the county auditor in any such appeal in which 587 the auditor is a party. If the commissioner is not a party to 588 the appeal or application before the board, the supreme court or 589 court of appeals, as applicable, shall not dismiss an appeal of 590 the board's decision because of the failure to make the 591 commissioner an appellee or to serve the notice of appeal to the 592 commissioner as otherwise required under this section.
The board, upon written demand filed by an appellant, 594 shall within thirty days after the filing of such demand file 595 with the court to which the appeal is being taken a certified 596 transcript of the record of the proceedings of the board 597 pertaining to the decision complained of and the evidence 598 considered by the board in making such decision.
If upon hearing and consideration of such record and 600 evidence the court decides that the decision of the board 601 appealed from is reasonable and lawful it shall affirm the same, 602 but if the court decides that such decision of the board is 603 unreasonable or unlawful, the court shall reverse and vacate the 604 decision or modify it and enter final judgment in accordance 605 with such modification.
The clerk of the court shall certify the judgment of the 607 court to the board, which shall certify such judgment to such 608 public officials or take such other action in connection 609 therewith as is required to give effect to the decision.
Any party to the appeal shall have the right to appeal 611 from the judgment of the court of appeals on questions of law, 612 as in other cases.
As used in this section, "taxpayer" includes any person 614 required to return any property for taxation.
Section 2. That existing sections 5715.19 and 5717.04 of 616 the Revised Code are hereby repealed.
Section 3. (A) The amendment by this act of division (G) 618 of section 5715.19 of the Revised Code applies to property tax 619 complaints filed on or after the effective date of this section. 620 (B) The enactment by this act of division (L) of section 621 5715.19 of the Revised Code applies to any complaint or counter- 622 complaint filed for tax years ending on or after the effective 623 date of that enactment.