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STRONGSVILLE BD. OF EDN. v. ZAINO

Nos. 00-841 and 00-842.

92 Ohio St.3d 488 (2001)

STRONGSVILLE BOARD OF EDUCATION, APPELLANT, v. ZAINO, TAX COMMR., ET AL., APPELLEES. EHRNFELT, MAYOR OF THE CITY OF STRONGSVILLE, APPELLANT, v. ZAINO, TAX COMMR., ET AL., APPELLEES.

Supreme Court of Ohio.

Decided August 15, 2001.

Attorney(s) appearing for the Case

Kolick & Kondzer and Daniel J. Kolick, for appellants.

Betty D. Montgomery, Attorney General, James C. Sauer and Janyce C. Katz, Assistant Attorneys General, for appellee Tax Commissioner.

Arter & Hadden, L.L.P., Bernard J. Smith and Irene C. Keyse-Walker, for appellee The Cleveland Clinic Foundation.

PFEIFER, J.

These two cases have been combined for oral argument and decision.

Factual and Procedural Background

On July 7, 1998, The Cleveland Clinic Foundation ("Clinic") filed an application with the Tax Commissioner to exempt from taxation certain real property in the Strongsville school district. The commissioner sent a notice dated August 24, 1998, to the Strongsville Board of Education ("BOE"), stating that an application...

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