Did Board of Revision Err in Adjusting Tax Value of Multiple Properties by Allocating Bulk Purchase Price?

FirstCal Industrial 2 Acquisitions, LLC v. Franklin County Board of Revision, the Franklin County Auditor and the Boards of Education of the South-Western City Schools and the Hilliard City Schools, Case no. 2009-1505

Ohio Board of Tax Appeals

ISSUE: When multiple parcels of real property within a county are purchased by the same buyer in a single transaction, and the sale is reported to the county auditor on a single conveyance form with only the aggregate purchase price listed, if the school districts in which those properties are located seek adjustment of the tax valuation of individual parcels, does a County Board of Revision err in adjusting the valuation of each parcel by allocating to it a percentage of the bulk sale price based on the county auditor's relative tax valuations of those properties prior to the bulk sale?