Green Local Schools Bd. of Edn. v. Manolakis

2019 Ohio 3250
CourtOhio Court of Appeals
DecidedAugust 14, 2019
Docket29196
StatusPublished

This text of 2019 Ohio 3250 (Green Local Schools Bd. of Edn. v. Manolakis) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Green Local Schools Bd. of Edn. v. Manolakis, 2019 Ohio 3250 (Ohio Ct. App. 2019).

Opinion

[Cite as Green Local Schools Bd. of Edn. v. Manolakis, 2019-Ohio-3250.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

GREEN LOCAL SCHOOLS BOARD OF C.A. No. 29196 EDUCATION

Appellee APPEAL FROM JUDGMENT and ENTERED IN THE OHIO BOARD OF TAX APPEALS SUMMIT COUNTY BOARD OF COUNTY OF SUMMIT, OHIO REVISION CASE No. 2017-1706

Appellee

v.

STAN MANOLAKIS, et al.

Appellants

DECISION AND JOURNAL ENTRY

Dated: August 14, 2019

CARR, Judge.

{¶1} Appellants Stan and Tiffany Manolakis appeal from the decision of the Ohio

Board of Tax appeals (“the BTA”). This Court affirms.

I.

{¶2} At the end of 2015, Mr. and Mrs. Manolakis purchased a home on Arlington Road

in North Canton via an online auction. They paid $800,000 plus additional fees for a total of

$836,299.00. The auditor assigned the property a value of $1,498,350 for 2016.

{¶3} In February 2017, Mr. and Mrs. Manolakis filed a complaint against the valuation

of real property with the Summit County Board of Revision (“the BOR”) seeking a decrease in 2

value to $800,000 based upon their recent purchase. Appellee Green Local School District

Board of Education (“Green”) filed a counter complaint seeking to maintain the value assigned

by the auditor.

{¶4} The matter proceeded to a hearing before the BOR at which Mr. Manolakis

testified. The BOR concluded that a decrease in valuation was warranted and valued the

property at $836,300 for the 2016 tax year.

{¶5} Green appealed to the BTA arguing that the auditor’s value should be reinstated

because Mr. and Mrs. Manolakis failed to meet their burden in the BOR to demonstrate that the

sale was an arm’s-length transaction. Absent such evidence, Green argued that the sales price

could not be considered the best evidence of value. The parties waived a hearing. While the

parties attached documents to their briefs in the BTA, the BTA refused to consider them as the

parties had “waiv[ed] the opportunity to supplement the record with new evidence at the [BTA]

hearing.”

{¶6} The BTA concluded that Mr. and Mrs. Manolakis failed to demonstrate that their

purchase of the property for $836,299 was an arm’s-length transaction. Ultimately, the BTA

concluded that “the evidence submitted at the BOR hearing was insufficient, and, therefore, the

BOR’s decision to reduce the subject property’s value to reflect the auction sale price is

unsupported.” Further, “[b]ecause there [wa]s no other evidence of value contained in the

record,” the BTA was “constrained to reinstate the subject property’s initially assessed value.”

{¶7} Mr. and Mrs. Manolakis have appealed, raising four assignments of error for our

review. They will be addressed together to facilitate the discussion of the relevant issues. 3

II.

ASSIGNMENT OF ERROR I

IT WAS UNREASONABLE OR UNLAWFUL FOR THE OHIO BOARD OF TAX APPEALS (BTA) TO REVERSE THE SUMMIT COUNTY BOARD OF REVISION (BOR) (APPENDIX A) DETERMINATION THAT THE FAIR MARKET VALUE OF THE SUBJECT PROPERTY IS $836,300 AS OF THE STATUTORY VALUATION DATE OF JANUARY 1, 2016 WHEN ALL OF THE EVIDENCE PROVES THAT IS THE TRUE VALUE OF THE SUBJECT PROPERTY, INCLUDING THAT WAS THE PRICE WHICH STAN AND TIFFANY MANOLAKIS (MANOLAKIS) PAID FOR THE PROPERTY LESS THAN TWO MONTHS BEFORE THE STATUTORY VALUATION DATE AT A PUBLIC AUCTION SALE OF THE SUBJECT PROPERTY WHICH WAS A VOLUNTARY SALE AT ARM’S LENGTH AND NOT A FORCED OR FORECLOSURE SALE OF THE PROPERTY.

ASSIGNMENT OF ERROR II

IT WAS UNREASONABLE OR UNLAWFUL FOR THE BTA TO EFFECTIVELY SHIFT THE BURDEN OF PROOF TO MANOLAKIS DURING THE PROCEEDINGS BEFORE THE BTA WHEN MANOLAKIS WAS NOT THE APPELLANT BEFORE THE BTA.

ASSIGNMENT OF ERROR III

ASSUMING THAT THE BURDEN OF PROOF ON APPEAL TO THE BTA HAD TO BE BORNE BY MANOLAKIS (WHICH IS DENIED), IT WAS UNREASONABLE OR UNLAWFUL TO FIND THAT MANOLAKIS DID NOT MEET THAT BURDEN OF PROOF.

ASSIGNMENT OF ERROR IV

IT WAS UNREASONABLE OR UNLAWFUL FOR THE BTA TO FIND THAT THE GREEN LOCAL SCHOOLS BOARD OF EDUCATION (GREEN) CARRIED ITS BURDEN OF PROOF AS APPELLANT BEFORE THE BTA WHEN GREEN OFFERED NO COMPETENT AND PROBATIVE EVIDENCE BEFORE EITHER THE BTA OR THE SUMMIT COUNTY BOR TO SUPPORT THE $1,498,350 VALUATION IT WAS ADVOCATING.

{¶8} Mr. and Mrs. Manolakis in their four assignments of error challenge the BTA’s

decision to reverse the ruling of the BOR and reinstate the value assigned by the auditor. They

argue in their first assignment of error that the evidence supports the BOR’s determination of

value. In their second assignment of error, they assert that the BTA improperly shifted the 4

burden of proof to them. Mr. and Mrs. Manolakis allege in their third assignment of error that,

assuming it was proper to shift the burden to them, they met their burden. Finally, in their fourth

assignment of error, they argue that Green failed to meet its burden to establish the $1,498,350

valuation.

{¶9} “We review BTA decisions only to determine whether they are ‘reasonable and

lawful.’ R.C. 5717.04. The court will defer to the BTA’s factual findings, including

determinations of a property’s value, as long as they are supported by ‘reliable and probative’

evidence in the record.” Olentangy Local Schools Bd. of Edn. v. Delaware Cty. Bd. of Revision,

141 Ohio St.3d 243, 2014-Ohio-4723, ¶ 21. “The BTA’s legal determinations, however, are

subject to de novo review.” Id.

{¶10} R.C. 5713.03 provides in relevant part that, “[i]n determining the true value of

any tract, lot, or parcel of real estate under this section, if such tract, lot, or parcel has been the

subject of an arm’s length sale between a willing seller and a willing buyer within a reasonable

length of time, either before or after the tax lien date, the auditor may consider the sale price of

such tract, lot, or parcel to be the true value for taxation purposes.” Nonetheless, R.C. 5713.04

states in pertinent part that “[t]he price for which such real property would sell at auction or

forced sale shall not be taken as the criterion of its value.” The Supreme Court of Ohio has

determined that the word “auction” in R.C. 5713.04 includes both voluntary and involuntary

auctions. Olentangy Local Schools Bd. of Edn. at ¶ 27. “Olentangy Local Schools [Bd. of Edn.]

made clear for the first time that all auction sales give rise to a presumption against using the sale

price as the property’s value, subject to rebuttal if the proponent proves the voluntary and arm’s-

length character of the sale.” Julia Realty, Ltd. v. Cuyahoga Cty. Bd. of Revision, 153 Ohio St.3d

262, 2018-Ohio-2415, ¶ 16. Thus, “the sale prices of parcels sold at auction are nevertheless the 5

best evidence of value when all of the elements of an arm’s-length transaction are present.”

Olentangy Local Schools Bd. of Edn. at ¶ 39.

{¶11} Under such circumstances, “the opponent of a sale price has a very light burden to

establish that a transaction was on its face an auction or a forced sale. Once that threshold is

crossed, then the proponent of the sale price bears the burden to prove that the sale was

nevertheless an arm’s-length transaction between typically motivated parties and should

therefore be regarded as the best evidence of the property’s value.” Id. at ¶ 43. “Whether a

transaction occurred at arm’s length depends on whether the sale was voluntary, whether it took

place on the open market, and whether the parties acted in their own self-interest.” North Canton

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2019 Ohio 3250, Counsel Stack Legal Research, https://law.counselstack.com/opinion/green-local-schools-bd-of-edn-v-manolakis-ohioctapp-2019.