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COVID-19 Relief Bill Did Not Extend Board of Revision Filing Deadline

In the case of Northridge Local Schools Bd. of Edn. v. Montgomery Cty. Bd. of Revision, 2022-Ohio-495, the Ohio Second District Court of Appeals affirmed the Board of Tax Appeals’ dismissal of a taxpayer’s property valuation complaint filed with the county board of revision (“BOR”) as untimely.

While R.C. 5715.19(A)(1) includes a deadline for filing complaints with the BOR — i.e., March 31 of the year after the tax year in question, here, the taxpayer filed after the March 31 deadline assuming that the COVID-19 Emergency Relief Bill (as passed by the Ohio General Assembly on March 27, 2020) extended the time limitations for filing BOR complaints, as well as criminal, civil, and administrative cases. The taxpayer assumed incorrectly.

In concluding that the COVID-19 Emergency Relief Bill did not extend the March 31 BOR complaint deadline, the Court explained that the legislation only applied to statutes of limitations and time limitations for filing cases, not deadlines such as the deadline for filing a BOR complaint. The Court further explained that the Governor even used a line-item veto to delete the phrase “or deadline” from the legislation.

To read this case, click here.

Authors: Matthew John Markling and the McGown & Markling Team.

Note: This blog entry does not constitute – nor does it contain – legal advice. Legal jurisprudence is like the always-changing Midwestern weather. As a result, this single blog entry cannot substitute for consultation with a McGown & Markling attorney. If legal advice is needed with respect to a specific factual situation, please feel free to contact a McGown & Markling attorney.

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