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GATX CORP. v. LIMBACH

No. 3291.

21 Ohio App. 3d 59 (1984)

GATX CORPORATION, APPELLANT, v. LIMBACH, TAX COMMR., APPELLEE.

Court of Appeals of Ohio, Trumbull County.

Decided November 16, 1984.

Attorney(s) appearing for the Case

Vorys, Sater, Seymour & Pease, Robert E. Leach, Kenneth D. Beck and Raymond D. Anderson, for appellant.

Anthony J. Celebrezze, Jr., attorney general, and James C. Sauer, for appellee.

DAHLING, J.

This is an appeal from a decision and order of the Board of Tax Appeals which affirmed the Tax Commissioner's certificate of final determination. We reverse and vacate the Board of Tax Appeals' order, and remand in accordance with this opinion.

The Board of Tax Appeals' decision and order in the instant cause contains the following findings of fact which are not disputed by GATX Corporation, appellant:

"GATX Corporation (fka General

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