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FINANCIAL CORP. v. PORTERFIELD

No. 70-170.

25 Ohio St. 2d 53 (1971)

CITIZENS FINANCIAL CORP., APPELLANT, v. PORTERFIELD, TAX COMMR., APPELLEE.

Supreme Court of Ohio.

Decided February 10, 1971.

Attorney(s) appearing for the Case

Mr. James F. Hadley, for appellant.

Mr. Paul W. Brown, attorney general, and Mr. C. Luther Heckman, for appellee.

HERBERT, J.

The appellant's first contention is that the decision of the Board of Tax Appeals is unreasonable and unlawful because the appellant's business activities as of the tax listing day, December 31, 1964 (R. C. 5725.14), did not constitute it a dealer in intangibles within the meaning of paragraph (B) of R. C. 5725.01.3 Upon an examination of the record, which reveals that Citizens...

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