Ohio Revised Code

Ohio Rev. Code § 5711.15 (2026)

Valuation of merchandise offered for sale

✓ current as of May 2026
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A merchant in estimating the value of the personal property held for sale in the course of his business shall take as the criterion the average value of such property, as provided in this section of the Revised Code, which he has had in his possession or under his control during the year ending on the day such property is listed for taxation, or the part of such year during which he was engaged in business. Such average shall be ascertained by taking the amount in value on hand, as nearly as possible, in each month of such year in which he has been engaged in business, adding together such amounts, and dividing the aggregate amount by the number of months that he has been in business during such year.

As used in this section a "merchant" is a person who owns or has in possession or subject to his control personal property within this state with authority to sell it, which has been purchased either in or out of this state, with a view to being sold at an advanced price or profit, or which has been consigned to him from a place out of this state for the purpose of being sold at a place within this state.

Notes of Decisions
Cited in 16 cases, 1958–2010 · leading case: Chicago Pac. Corp. v. Limbach, 605 N.E.2d 8 (Ohio 1992).
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Chicago Pac. Corp. v. Limbach, 605 N.E.2d 8 (Ohio 1992). · cites it 8× “R.C. 5711.15 provides: “A merchant in estimating the value of the personal property held for sale in the course of his business shall take as the criterion the average value of such property, as provided in this section of the Revised Code, which he has had in his business or…”
Harsco Corp. v. Tracy, 712 N.E.2d 1249 (Ohio 1999). · cites it 3× “2d 1137, 1138 , a case interpreting R.C. 5711.15, which directs the averaging of inventory held by a merchant, we stated: “[W]e have long and consistently held that a merchant must include in the calculations any inventory it held even if it did not hold inventory for a full…”
Rick Case Motors, Inc. v. Tracy, 643 N.E.2d 1137 (Ohio 1994). · cites it 4× “R.C. 5711.15 describes how a merchant should value his inventory: “A merchant in estimating the value of the personal property held for sale in the course of his business shall take as the criterion the average value of such property, as provided in this section of the Revised…”
Rich's Dep't Stores, Inc. v. Levin, 2010 Ohio 957 (Ohio 2010). · cites it 2× “See R.C. 5711.15 (merchant ascertains value of inventory by computing 12-month average of inventory on hand).”
Rowe-Reilly Corp. v. Tracy, 710 N.E.2d 694 (Ohio 1999). · cites it 7× “” We note preliminarily that we agree with the BTA’s determination that appellant is a “merchant” as that term is defined by R.C. 5711.15. However, we do not agree with the remainder of the majority decision of the BTA in this cause.”
Zalud Oldsmobile, Inc. v. Limbach, 628 N.E.2d 1382 (Ohio 1994). “R.C. 5711.15 requires a merchant to estimate the value of personal property held for sale as of tax lien date by averaging his month-end inventory values.”
Doraty Rambler, Inc. v. Schneider, 212 N.E.2d 580 (Ohio 1965). · cites it 18× “” As an exception to this general rule, Section 5711.15, Revised Code, provides that a “merchant” may ascertain such average value on the basis of his prior year “by taking the amount in value on hand * * * in each month of such year, in which he has been engaged in business,…”
Rowe-Reilly Corp. v. Tracy, 1999 Ohio 326 (Ohio 1999). · cites it 7× “” {¶ 13} We note preliminarily that we agree with the BTA’s determination that appellant is a “merchant” as that term is defined by R.C. 5711.15. However, we do not agree with the remainder of the majority decision of the BTA in this cause.”
Rick Case Motors, Inc. v. Tracy, 1994 Ohio 176 (Ohio 1994). · cites it 4× “R.C. 5711.15 describes how a merchant should value his inventory: "A merchant in estimating the value of the personal property held for sale in the course of his business shall take as the criterion the average value of such property, as provided in this section of the Revised…”
Beerman Stores, Inc. v. Bowers, 173 Ohio St. (N.S.) 59 (Ohio 1962). · cites it 6× “Does the fact that such inventory was destroyed by fire prior to tax listing day relieve appellee from including such inventory in its return? Section 5711.15, Revised Code, recognizes that a merchant may not have an inventory in existence for a full year period and makes…”
Harsco Corp. v. Tracy, 1999 Ohio 155 (Ohio 1999). · cites it 3× “2d 1137, 1138 , a case interpreting R.C. 5711.15, which directs the averaging of inventory held by a merchant, we stated: “[W]e have long and consistently held that a merchant must include in the calculations any inventory it held even if it did not hold inventory for a full…”
United Eng'g & Foundry Co. v. Bowers, 171 Ohio St. (N.S.) 279 (Ohio 1960). · cites it 3× “Section 5711.15, Revised Code, as in effect in 1956, relative to the listing of merchandise for sale, provided that a merchant in estimating the value of personal property “held for sale in the course of his business shall take as the criterion the average value of such…”
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