ISSUES:

- Did the Pike County auditor act in bad faith and with frivolous conduct when in 2010 he assessed the private operator of a federal government-owned uranium enrichment plant for personal property taxes owed for tax year 1993?

- Did the Board of Tax Appeals commit an error when it upheld the cancellation of the tax assessment, but ignored the operator's request for a ruling of bad faith that would allow it to appeal to the Ohio Supreme Court for attorney fees?

- Did the Ohio tax commissioner and the Board of Tax Appeals wrongly determine that the U.S. Department of Energy, and not the private contractor, was the manufacturer of enriched uranium, which exempted the operator from payment of personal property tax?