Per Curiam.
R.C. 5711.15 provides:
"A merchant in estimating the value of the personal property held for sale in the course of his business shall take as the criterion the average value of such property, as provided in this section of the Revised Code, which he has had in his business or under his control during the year ending on the day such property is listed for taxation, or the part of such year during which he was engaged in business. Such average...
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