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SFZ TRANSP., INC. v. LIMBACH

No. 92-1481.

66 Ohio St.3d 602 (1993)

SFZ TRANSPORTATION, INC., APPELLANT, v. LIMBACH, TAX COMMR., APPELLEE.

Supreme Court of Ohio.

Decided June 30, 1993.

Attorney(s) appearing for the Case

Jones, Day, Reavis & Pogue and John C. Duffy, Jr., for appellant.

Lee I. Fisher, Attorney General, and Richard C. Farrin, Assistant Attorney General, for appellee.

Per Curiam.

In Proposition of Law No. 1, SFZ argues that the BTA's ultimate legal conclusions concerning Ex. 3 were unlawful and that its conclusion as to the primary use of the equipment was unreasonable. It asserts that the entire record establishes that the primary use of the equipment was in the common carrier business and that the equipment, consequently, was used directly in the rendition of a public utility...

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