ILED. HAND DELlVERE6 JUNO IN THE SUPREME COURT STATE OF OHIO APPEAL FROM THE OHIO BOARD OF TAX APPEALS BOARD OF TAX APPEALS COLUMBUS. OHIO ^'.

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1 IN THE SUPREME COURT STATE OF OHIO APPEAL FROM THE OHIO BOARD OF TAX APPEALS COPLEY-FAIRLAWN SCHOOL DISTRICT BOARD OF EDUCATION Appellee, SUMMIT COUNTY BOARD OF REVISION, Appellant, SUPREME COURT CASE NUMBER:..4i ^ ^'. '/ ^^ ^, /f.,,,/ p :t.,..^.,:^ Y ^.. r^ i 5.. ^.mrr ^^ BTA CASE NO (Lower Case No (REAL PROPERTY TAX f TEAM RENTALS, LLC Appellant. ^'. ;'i >-> r' ;.,, s 4^ r Ci+...,La tisi it{:: ": e'` Y^ ' ' r ',r,^p,r tis'o':-/--, 3.i^ ^^`^5. <l^:,,.. c: NOTICE OF APPEAL 'I'homas A, Skidmore, Esq. (# THOMAS A. SKIDMORE CO., L.P.A. One Cascade Plaza, 12t" Floor PNC Center Building Phone: ( Fax: ( Karrie M. Kalail, Esq. (# BRITTON, SMITH, PETERS & KALAIL CO., L.P.A 3 Summit Drive, Suite 400 Clevel, Ohio Phone: ( Fax: ( kkkiiaii0?ohioedlaw.c;oin Milton C. Rankins, Esq. Assistant Prosecuting Attorney SHERRI BEVAN NYALSH SUMMIT COUNTY PROSECUTING ATTORNEY 53 University Avenue, 6th Floor Phone: ( Fax: ( HAND DELlVERE6 ILED JUNO BOARD OF TAX APPEALS COLUMBUS. OHIO

2 IN THE SUPREME COURT STATE OF OHIO APPEAL FROM THE OHIO BOARD OF TAX APPEALS COPLEY-FAIRLAWN SCHOOL DISTRICT BOARD OF EDIJCATION SUPREME COURT CASE NUMBER: Appellee, SUMMIT COUNTY BOARD OF REVISION, Appellant, BTA CASE NO (Lower Case No (REAL PROPERTY TAX TEAM RENTALS, LLC Appellant. The Appellant, TEAM RENTALS, LLC by through its undersigned counsel, hereby gives notice of its appeal to the Supreme Court of the State of Ohio, from a Decision Order of the Ohio Board of 'I`ax Appeals, rendered on the 9th day of May, 2014, a copy of which is attached hereto as "Exhibit A" which is incorporated herein as though fully rewritten in this Notice of Appeal. The errors complained of are attached hereto as "Exhibit B," which is incorporated herein by reference." Respectfully submitted, THOMAS A. SKIDMORE CO., L.P.A. One PNC Phone: Fax: A. SIMORE, ESQ. (# le Ph a. 12th Floor ;nter Building Ohio ( ( t[iortiassl,idnzorr fi-.r: bdznet.com

3 Copley-Fairlawn City School District Board of Education, vs. OHIO BOARD OF TAX APPEALS Appellant(s, Summit County Board of Revision, et al, APPEARANCES: Appellees. CASE NO(S (REAL PROPERTY TA.X DECISION AND ORDER For the Appellant(s - Britton, Smith, Peters & Kalail Co., LPA Karrie M. Kalail 3 Summit Park Drive, Suite 400 Clevel, Ohio For the County Appellees Entered Y 09 For the Appellee Property Owner - Sherri Bevan Walsh Summit County Prosecuting Attorney Milton C. Rankins Assistant Prosecuting Attorney 53 University Avenue, 6t" Floor - Thomas Skidmore Attomey at Law 1 Cascade Plaza, 12"' Floor EXtilB!T a k Mr. Williamson, Mr. Johrendt, Mr. Harbarger concur. Appellant(s appeals a decision of the board of revision ("BOR" which determined the value of the subject real property, parcel number(s , , This matter is now considered upon the notice of appeal, the transcript certified by the BOR pursuant to R.C , the record of this board's hearing. The subject's total true value was initially assessed at $1,362,930. A decrease complaint was filed with the BOR seeking a reduction in value to $1,125,000. The appellant filed a countercomplaint advocating for the retention of the fiscal officer's values. At the hearing before the BOR, the subject property was described as a multi-tenant office building. Theodore KliYnczak, managing member of the appellee property owner company, testified that the subject property has suffered from vacancy issues will be in need of repairs due to its age. He explained that his business is a tenant in the building, so he has to pay above market rents to cover the subject property's costs, he could not refinance the building for the county's assessed value. The property owner presented an appraisal report, absent its author, completed for refinancing purposes, with an effective date of June 14, 2011 in support of its opiruon of value of $1,125,000, as well as income tax schedules from Counsel for the appellant then cross-examined Klimczak. The BOR issued a decision decreasing the initially

4 PARCEL NUMBER TRUE VALUE TAXABLE VALUE with this decision order $1,271,960 $445, $ 23,440 $ 8, $ 67,530 $ 23,640 It is the order of the Board of T'ax Appeals that the subject property be assessed in conformity I hereby certify the foregoing to be a true complete copy of the action taken by the Board of Tax Appeals of the State of Ohio entered upon its journal this day, with respect to the captioned matter. e., 1.6 A.J. Groeber, Board Secretary 3

5 ASSIGNMENT OF ERROR NO. 1: EXHIBIT B ASSIGNMENT OF ERRORS The Board of Tax Appeals' Decision Order dated May 9, 2014 finding the true value of the Appellant's real property for Parcel # was $1,271, with taxable value of $445, Parcel # with true value of $23,440 taxable value of $8, Parcel # with true value of $67, taxable value of $23, are unreasonable unlawful. ASSIGNMENT OF ERROR NO. 2: The Appellee, Copley-Fairlawn School District Board of Education, presented no evidence valuation in relation to the Appellant, Team Rentals, LLC properties, failed to meet its burden of proof as to the value requested therefore the Ohio Board of Tax Appeals is unreasonable unlawful. ASSIGNMENT OF ERROR NO. 3; The Board of Tax Appeals Decision Order dated May 9, 2014 is premised upon no evidence submitted by the Appellee, Copley-Fairlawn School District Board of Education therefore lacks the requisite elements to reverse a Board of Revision decision which was based upon documentation, testimony evidence submitted which said reversal is unreasonable unlawful. ASSIGNMENT OF ERROR NO. 4: 'The Board of 'Tax Appeals Decision Order dated May 9; 2014 reinstating the value of Parcel's owned by the Appellant, TEAM RENTALS, LLC is unlawful unreasonable because the Appellee failed to satisfy its burden of showing that the character of the property or market conditions had not changed. ASSIGNMENT OF ERROR NO. 5: The Board of Tax Appeals' Decision Order dated May 9, 2014 violates Article XII, Section 2 of the Ohio Constitution which requires that property must be taxed by uniform rule according to value. ASSIGNMENT OF ERROR NO. 6: The Board of Tax Appeals' Decision Order dated May 9, 2014 violates Article I, Section 2 of the Ohio Constitution which provides that Government is institued for the equal protection benefit of the people.

6 ASSIGNMENT OF ERROR NO. 8: The Board of 'Tax Appeals' Decision Order violates the Equal Protection Clause of Amendment XIV of the Constitution of the United States of America.

7 CERTIFICATE OF SERVICE A copy of the foregoing Notice of Appeal was sent via regular U.S. Mail, postage prepaid thi ^ day of June, 2013 to the following: Karrie M. Kalail, Esq. Paul J. Deegan, Esq. Sarah E. Kutscher, Esq. BRITTON, SMITH, PETERS & KALAIL CO., L.P.A. Attorneys for Appellant, Copley-Fairlawn SD BOE 3 Summit Park- Drive, Suite 400 Clevel, Ohio Milton C. Rankins, Esq. Assistant Prosecuting Attorney SHERRI BEVAN WALSH SUMMIT COUNTY PROSECUTING ATTORNEY 53 University Avenue, 6th Floor