SEVEN HILLS SCHOOLS v. KINNEY

No. 86-630.

28 Ohio St. 3d 186 (1986)

SEVEN HILLS SCHOOLS, APPELLANT, v. KINNEY, COMMR., APPELLEE.

Supreme Court of Ohio.

Decided December 26, 1986.


Attorney(s) appearing for the Case

Taft, Stettinius & Hollister and Daniel J. Hoffheimer, for appellant.

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


Per Curiam.

The issue before us is whether the property in question is entitled to tax-exempt status pursuant to R.C. 5709.07, 5709.12, and 5709.121(A) and (B). For the reasons to follow we affirm the BTA and deny the exemption.

The standard of review in this instance is well-established. Exemption is the exception to the rule and statutes granting exemptions are strictly construed. Our duty is limited to determination of whether the decision of

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