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MUTUAL INS. CO. v. BOWERS

Nos. 39142 and 39143.

5 Ohio St. 2d 12 (1965)

THE CELINA MUTUAL INS. CO., APPELLEE AND CROSS-APPELLANT, v. BOWERS, TAX COMMR., APPELLANT AND CROSS-APPELLEE. THE NATIONAL MUTUAL INS. CO., APPELLEE AND CROSS-APPELLANT, v. BOWERS, TAX COMMR., APPELLANT AND CROSS-APPELLEE.

Supreme Court of Ohio.

Decided December 29, 1965.

Attorney(s) appearing for the Case

Messrs. Vorys, Sater, Seymour & Pease, Mr. Arthur I. Vorys, Mr. Duke W. Thomas and Mr. Jerry D. Jordan, for appellees and cross-appellants.

Mr. William B. Saxbe, attorney general, and Mr. Edgar L. Lindley, for appellant and cross-appellee.

ZIMMERMAN, J.

In support of their position and the favorable judgments of the Court of Appeals, appellees rely on Section 5725.25, Revised Code, first effective in 1931 and which has remained in substantially the same form ever since. That section, as applicable and pertinent, reads:

"The real estate of a domestic insurance company shall be taxed in the place where it is located, the same as the real estate of other persons is taxed, but the tax provided for...

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