Ohio Revised Code

Ohio Rev. Code § 5711.16 (2026)

Listing of personal property by manufacturer - average value of articles

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(A) As used in this section:

(1) "Manufacturer" means a person who purchases, receives, or holds personal property for the purpose of adding to its value by manufacturing, refining, rectifying, or combining different materials with a view of making a gain or profit by so doing.

(2) "Manufacturing equipment" means machinery and equipment, and tools and implements, including any associated patterns, jigs, dies, drawings, and business fixtures, used at a manufacturing facility by a manufacturer, and includes any such property leased to the manufacturer. "Manufacturing equipment" excludes property used for general office purposes. Nothing in this division is to be construed to change the definition of personal property, as defined in section 5701.03 of the Revised Code.

(3) "Manufacturing facility" means a facility or portion of a facility used for manufacturing, mining, refining, rectifying, or combining different materials with a view of making a gain or profit by so doing. "Manufacturing facility" includes that portion of a facility used to store or transport raw materials, work-in-process, or finished goods inventory, for packaging, for research, or to test for quality control, as long as manufacturing, mining, refining, rectifying, or combining is also performed at the facility. "Manufacturing facility" does not include any portion of a facility used primarily for making retail sales.

(4) "Manufacturing inventory" means all articles purchased, received, or otherwise held for the purpose of being used, in whole or in part, in manufacturing, mining, combining, rectifying, or refining, and of all articles that were at any time manufactured or changed in any way by a manufacturer, either by mining, combining, rectifying, refining, or adding thereto.

(B) When a manufacturer is required to return a statement of the amount of the manufacturer's personal property used in business, the manufacturer shall include the average value, estimated as provided in this section, of manufacturing inventory that the manufacturer has had on hand during the year ending on the day the property is listed for taxation annually, or the part of such year during which the manufacturer was engaged in business. The manufacturer shall separately list finished products not kept or stored at the place of manufacture or at a warehouse in the same county.

The average value of such property shall be ascertained by taking the value of all property subject to be listed on the average basis, owned by the manufacturer on the last business day of each month the manufacturer was engaged in business during the year, adding the monthly values together, and dividing the result by the number of months the manufacturer was engaged in such business during the year. The result shall be the average value to be listed.

(C) A manufacturer also shall list all manufacturing equipment owned or used by the manufacturer.

Notes of Decisions
Cited in 34 cases, 1954–2015 · leading case: Ares, Inc. v. Limbach, 554 N.E.2d 1310 (Ohio 1990).
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Ares, Inc. v. Limbach, 554 N.E.2d 1310 (Ohio 1990). · cites it 6× “R.C. 5711.16 provides: “A person who purchases, receives, or holds personal property for the purpose of adding to its value by manufacturing, refining, rectifying, or combining different materials with a view of making a gain or profit by so doing is a manufacturer.”
Cleveland Gear Co. v. Limbach, 520 N.E.2d 188 (Ohio 1988). · cites it 3× “Although appellant makes the prefatory statement that R.C. 5711.16 is facially discriminatory, its argument stresses the specific facts of record.”
Stoneco, Inc. v. Limbach, 560 N.E.2d 578 (Ohio 1990). · cites it 3× “R.C. 5711.16 states: “A person who purchases, receives, or holds personal properly for the purpose of adding to its value by manufacturing, refining, rectifying, or combining different materials with a view of making a gain or profit by so doing is a manufacturer.”
Harsco Corp. v. Tracy, 712 N.E.2d 1249 (Ohio 1999). · cites it 4× “R.C. 5711.16 sets forth how a manufacturer lists its inventory for the personal property tax: “When [a manufacturer] is required to return a statement of the amount of his personal property used in business, he shall include the average value, estimated as provided in this…”
J.M. Smucker, L.L.C. v. Levin, 865 N.E.2d 866 (Ohio 2007). “2d 1249 (construing R.C. 5711.16, which addresses valuation of the inventory of manufacturers).”
Limbach v. Hooven & Allison Co., 466 U.S. 353 (1984). “In accord with Ohio Rev. Code Ann. §5711.16 (1980), Hooven timely filed personal property tax returns for 1976 and 1977.”
Snodgrass v. Testa (Slip Opinion), 2015-Ohio-5364, 50 N.E.3d 475. · cites it 2× “{¶ 21} Additionally, the BTA held that the PILOT agreement barred the assessment, as did, in the BTA’s view, the ten-year statute of limitations of R.”
Hoover Universal, Inc. v. Limbach, 575 N.E.2d 811 (Ohio 1991). · cites it 2× “The credit shall equal the lesser of the amount of tax otherwise due under such chapter or the difference between: “(A) The tangible personal property taxes timely paid in the taxable year that were charged against engines, machinery, tools, and implements owned *565 by the…”
Chicago Pac. Corp. v. Limbach, 605 N.E.2d 8 (Ohio 1992). · cites it 2× “Chapter 5711 requires listing the average value of manufacturing inventory. According to Justice Brown, the method proposed by the taxpayer in that case, which is similar to the argument posited in the instant case, does not yield an average because the numerator has a number…”
ATS Ohio, Inc. v. Tracy, 667 N.E.2d 937 (Ohio 1996). · cites it 6× “The issue before the court is whether equipment under production for which progress payments have been received constitutes inventory “owned” by the manufacturer for purposes of R.C. 5711.16 and is subject to inclusion on the manufacturer’s return as personal property.”
Pittsburgh-Des Moines Steel Co. v. Lindley, 437 N.E.2d 302 (Ohio 1982). · cites it 3× “” R.C. 5711.16 provides, in pertinent part: “A person who purchases, receives, or holds personal property for the purpose of adding to its value by manufacturing, refining, rectifying, or combining different materials with a view of making a gain or profit by so doing is a…”
Gen. Am. Transp. Corp. v. Limbach, 473 N.E.2d 814 (Ohio 1984). · cites it 5× “R.C. 5711.16 defines a “manufacturer” to be: *304 “A person who purchases, receives, or holds personal property for the purpose of adding to its value by manufacturing * * * different materials with a view of making a gain or profit by so doing * * (Emphasis added.”
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