JOHN C. YOUNG, Judge.
This matter is before this court upon the appeal of the Franklin County Auditor, the Board of Revision of Franklin County ("BOR"), and the Board of Education of the City of Columbus School District, appellants, from the February 2, 1996 decision and order issued by the Ohio Board of Tax Appeals ("BTA"). Appellants set forth the following assignment of error:
"The decision of the Ohio Board of Tax Appeals (BTA) was unreasonable and unlawful...
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