KIN, Inc. v. Trumbull Cty. Bd. of Revision

2025 Ohio 2305
CourtOhio Court of Appeals
DecidedJune 30, 2025
Docket2024-T-0104, 2024-T-0105
StatusPublished

This text of 2025 Ohio 2305 (KIN, Inc. v. Trumbull Cty. Bd. of Revision) 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
KIN, Inc. v. Trumbull Cty. Bd. of Revision, 2025 Ohio 2305 (Ohio Ct. App. 2025).

Opinion

[Cite as KIN, Inc. v. Trumbull Cty. Bd. of Revision, 2025-Ohio-2305.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT TRUMBULL COUNTY

KIN, INC., CASE NOS. 2024-T-0104 2024-T-0105 Appellant, Administrative Appeals from the - vs - Ohio Board of Tax Appeals

TRUMBULL COUNTY BOARD OF REVISION, et al., Trial Court Nos. 2024-0912 2024-0913 Appellees.

OPINION AND JUDGMENT ENTRY

Decided: June 30, 2025 Judgment: Affirmed

Cecilia J. Hyun, Siegel Jennings Co., LPA, 23425 Commerce Park, Suite 103, Cleveland, OH 44122 (For Appellant).

Dennis Watkins, Trumbull County Prosecutor, and Lynn B. Griffith, III, Assistant Prosecutor, Administration Building, Fourth Floor, 160 High Street, N.W., Warren, OH 44481 (For Appellee, Trumbull County Board of Revision).

Lindsey M. Harrison Madgar, 5577 Youngstown-Warren Road, Niles, OH 44446 (For Appellee, Howland Commons, LLC).

Karrie M. Kalail, Peters, Kalail & Markakis Co., LPA, 6480 Rockside Woods Boulevard, S., Suite 300, Cleveland, OH 44131 (For Appellee, Howland Local Schools Board of Education).

MATT LYNCH, J.

{¶1} Appellant, KIN, Inc., appeals from the decisions of the Ohio Board of Tax

Appeals (“BTA”) that upheld the dismissal of KIN, Inc.’s valuation complaints for lack of

standing and denied its motion for reconsideration. For the foregoing reasons, we affirm

the BTA’s decisions. {¶2} KIN, Inc. leases property owned by Howland Commons, LLC (“the landlord”

or “the property owner”), from which it operates a Kohl’s discount store and a junior

department store in Howland, Ohio. In March 2023, KIN, Inc. filed with the Trumbull

County Board of Revision (“the BOR” or “the board”) two complaints contesting the

valuation of the property for the 2023 tax year. Although the properties for each store

have different addresses and were valued separately, they concern the same economic

unit.

{¶3} The complaint filed in case No. 389 concerned parcel No. 28-902680,

located at 2350 Niles Cortland Road. KIN, Inc. contested the Trumbull County auditor’s

assessment that the true value (i.e., the fair market value) of the property is $4,301,400,

contending it should be $3,427,200 (a difference of $874,200). The Howland Board of

Education filed a counter-complaint, asserting the auditor’s assessment is correct.

{¶4} The complaint filed in case No. 390 concerned parcel No. 20-042107,

located at Mines Road. KIN, Inc. contested the Trumbull County auditor’s assessment

that the true value of the property is $91,400, contending the value should be $72,800 (a

difference of $18,600).

{¶5} In July 2024, the BOR held a hearing in which it dismissed KIN, Inc.’s

complaints for lack of subject matter jurisdiction because KIN, Inc., a tenant, did not

establish it had standing. In its written decision, the board explained that pursuant to R.C.

5715.19(A)(1)(f), a complaint can be filed by a tenant only if the tenant meets certain

conditions, i.e., the property is classified as commercial or industrial; the lease requires

the tenant to pay the entire amount of taxes charged against the property; and “the lease

allows, or the property owner otherwise authorizes,” the tenant to file such a complaint.

PAGE 2 OF 13

Case Nos. 2024-T-0104, 2024-T-0105 {¶6} The BOR verified the property is classified as commercial from the records

of the Trumbull County Auditor’s Office. KIN, Inc. had also supplied the board with a copy

of its lease, and the board found two relevant sections. First, pursuant to Section 7.1 of

the lease, the tenant is required to pay the entire amount of taxes charged to the property.

Second, Section 7.4, “Tax Contests,” provides, in relevant part:

At tenant’s request, Landlord shall contest in good faith by appropriate proceedings, or in any other manner permitted by law, at Tenant’s expense, in Landlord’s name, any taxes assessed or levied against the Shopping Center or Tenant’s Tracts, if separately assessed, and Tenant agrees to cooperate with Landlord and to execute any documents reasonably required for such purpose. . . .

{¶7} The BOR reviewed that at the hearing it had inquired whether KIN, Inc. had

any other documentation that satisfied the criteria of R.C. 5715.19(A)(1)(f), since the

lease did not authorize the tenant to file a valuation complaint. KIN, Inc. had stated that

such documentation did exist and would be forwarded to the board for review. KIN, Inc.

sent the board an email from the landlord’s legal counsel to the county auditor, dated

June 12, 2024, which stated in relevant part, “Our tenant Kohl’s is pursuing these

valuation complaints.” The board found this was not sufficient authorization from the

property owner to the tenant under R.C. 5715.19(A)(1)(f), because

it is a statement of fact of the actions of the Complainant [KIN, Inc.] made to the Auditor’s representative. Even if the Board found it to grant authorization in this matter, it is dated June 12, 2024, well after the filing of the complaint on March 20, 2024, and is not sufficient to establish the Complainant’s standing as of the date of filing of the complaint. Complainant supplied no further documentation to be reviewed and made no additional indication to the Board that other documentation exists, so it is assumed that such documentation does not exist to establish Complainant’s standing and invoke the jurisdiction of the Board.

{¶8} Finding KIN, Inc. could not establish standing to contest the valuations, the

BOR dismissed the complaints.

PAGE 3 OF 13

Case Nos. 2024-T-0104, 2024-T-0105 {¶9} In August 2024, KIN, Inc. filed appeals with the BTA.

{¶10} The BOR filed a motion to dismiss, contending the appeals should be

dismissed because KIN, Inc. failed to submit any evidence of the landlord’s consent to

file the valuation complaints, which was required to establish standing.

{¶11} KIN, Inc. filed a brief in opposition and attached a 2009 amendment to the

lease. In relevant part, Section 7.4, “Tax Contests,” had been amended to include the

following paragraph:

Notwithstanding the provisions of the foregoing paragraph, Tenant may provide Landlord with a written request for Landlord to consent to Tenant making a direct appeal to the taxing authority concerning the taxes assessed or levied against Tenant’s Tract. Such request shall set forth, in specific detail, the reason(s) that Tenant desires to make said appeal. Within thirty (30) days of receiving Tenant’s request, Landlord shall provide Tenant with a notice stating whether or not it consents to Tenant’s request. Landlord’s consent shall not be unreasonably withheld, conditioned or delayed. If Tenant requests Landlord’s consent to Tenant filing a property tax appeal on the taxes assessed against Tenant’s Tract, then Tenant shall be solely responsible for all costs related to such appeal. Landlord shall have no obligation for any such costs and Tenant shall not be obligated to Landlord for any tax advisory fees.

{¶12} In November 2024, the BTA issued a decision and order affirming the

BOR’s decision dismissing KIN, Inc.’s complaints for lack of standing. The BTA found

KIN, Inc.’s argument—that the 2009 amendment to Section 7.4, “Tax Contests,” gave it

the right to file a valuation complaint—“is not faithful to the text.” (Nov. 13, 2024 BTA

Decision and Order, p. 3.) Rather, the provision provided for a procedure whereby KIN,

Inc. could request consent from the landlord, and the landlord, in turn, would provide KIN,

Inc. with notice of consent. The board also found KIN, Inc.’s reading of the email from

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Bluebook (online)
2025 Ohio 2305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kin-inc-v-trumbull-cty-bd-of-revision-ohioctapp-2025.