Ohio Revised Code

Ohio Rev. Code § 5715.27 (2026)

Application for exemption - rights of board of education - complaint against exemption

✓ current as of May 2026
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(A)(1) Except as provided in division (A)(2) of this section and in section 3735.67 of the Revised Code, the owner, a vendee in possession under a purchase agreement or a land contract, the beneficiary of a trust, or a lessee for an initial term of not less than thirty years of any property may file an application with the tax commissioner, on forms prescribed by the commissioner, requesting that such property be exempted from taxation and that taxes, interest, and penalties be remitted as provided in division (C) of section 5713.08 of the Revised Code.

(2) If the property that is the subject of the application for exemption is any of the following, the application shall be filed with the county auditor of the county in which the property is listed for taxation:

(a) A public road or highway;

(b) Property belonging to the federal government of the United States;

(c) Additions or other improvements to an existing building or structure that belongs to the state or a political subdivision, as defined in section 5713.081 of the Revised Code, and that is exempted from taxation as property used exclusively for a public purpose;

(d) Pre-residential development property that is exempted from taxation pursuant to section 5709.56 of the Revised Code.

(B)(1) The board of education of any school district may request the tax commissioner or county auditor to provide it with notification of applications for exemption from taxation for property located within that district. If so requested, and except as provided in division (B)(2) of this section, the commissioner or auditor shall send to the board on a monthly basis reports that contain sufficient information to enable the board to identify each property that is the subject of an exemption application, including, but not limited to, the name of the property owner or applicant, the address of the property, and the auditor's parcel number. The commissioner or auditor shall mail the reports by the fifteenth day of the month following the end of the month in which the commissioner or auditor receives the applications for exemption.

(2) A county auditor shall not provide a board of education with notification of an application for exemption from taxation for pre-residential development property filed pursuant to section 5709.56 of the Revised Code.

(C) A board of education that has requested notification under division (B)(1) of this section may, with respect to any application for exemption of property located in the district and included in the commissioner's or auditor's most recent report provided under that division, file a statement with the commissioner or auditor and with the applicant indicating its intent to submit evidence and participate in any hearing on the application. The statements shall be filed prior to the first day of the third month following the end of the month in which that application was docketed by the commissioner or auditor. A statement filed in compliance with this division entitles the district to submit evidence and to participate in any hearing on the property and makes the district a party for purposes of sections 5717.02 to 5717.04 of the Revised Code in any appeal of the commissioner's or auditor's decision to the board of tax appeals.

(D) The commissioner or auditor shall not hold a hearing on or grant or deny an application for exemption of property in a school district whose board of education has requested notification under division (B)(1) of this section until the end of the period within which the board may submit a statement with respect to that application under division (C) of this section. The commissioner or auditor may act upon an application at any time prior to that date upon receipt of a written waiver from each such board of education, or, in the case of exemptions authorized by section 725.02, 1728.10, 5709.40, 5709.41, 5709.411, 5709.45, 5709.62, 5709.63, 5709.632, 5709.73, 5709.78, 5709.84, or 5709.88 of the Revised Code, upon the request of the property owner. An auditor may act at any time on an application about which the board of education is not authorized to receive notice under division (B)(2) of this section. Failure of a board of education to receive the report required in division (B)(1) of this section shall not void an action of the commissioner or auditor with respect to any application. The commissioner or auditor may extend the time for filing a statement under division (C) of this section.

(E) A complaint may also be filed with the commissioner or auditor by any person, board, or officer authorized by section 5715.19 of the Revised Code to file complaints with the county board of revision against the continued exemption of any property granted exemption by the commissioner or auditor under this section other than pre-residential development property that is exempted from taxation pursuant to section 5709.56 of the Revised Code.

(F) An application for exemption and a complaint against exemption shall be filed prior to the thirty-first day of December of the tax year for which exemption is requested or for which the liability of the property to taxation in that year is requested. The commissioner or auditor shall consider such application or complaint in accordance with procedures established by the commissioner, determine whether the property is subject to taxation or exempt therefrom, and, if the commissioner makes the determination, certify the determination to the auditor. Upon making the determination or receiving the commissioner's determination, the auditor shall correct the tax list and duplicate accordingly. If a tax certificate has been sold under section 5721.32 or 5721.33 of the Revised Code with respect to property for which an exemption has been requested, the tax commissioner or auditor shall also certify the findings to the county treasurer of the county in which the property is located.

(G) Applications and complaints, and documents of any kind related to applications and complaints, filed with the tax commissioner or county auditor under this section are public records within the meaning of section 149.43 of the Revised Code.

(H) If the commissioner or auditor determines that the use of property or other facts relevant to the taxability of property that is the subject of an application for exemption or a complaint under this section has changed while the application or complaint was pending, the commissioner or auditor may make the determination under division (F) of this section separately for each tax year beginning with the year in which the application or complaint was filed or the year for which remission of taxes under division (C) of section 5713.08 of the Revised Code was requested, and including each subsequent tax year during which the application or complaint is pending before the commissioner or auditor.

Last updated July 8, 2024 at 12:51 PM

Notes of Decisions
Cited in 39 cases (3 in the last 5 years), 1967–2026 · leading case: Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001).
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Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). · cites it 46× “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). · cites it 35× “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
ShadoArt Prods., Inc. v. Testa (Slip Opinion), 2016 Ohio 511 (Ohio 2016). · cites it 42× “{¶ 1} This real-property-tax exemption case turns on the relationship between R.C. 5715.27, which authorizes the filing of exemption applications and specifies who has standing to file one, and R.”
Cincinnati City Sch. Dist. Bd. of Edn. v. Testa (Slip Opinion), 2014 Ohio 4647 (Ohio 2014). · cites it 41× “{¶ 1} This appeal involves appellee the city of Cincinnati’s application for exemption from real-property tax for property that constitutes part of the city’s convention center, the Duke Energy Center.”
City of Toledo v. Levin, 117 Ohio St. 3d 373 (Ohio 2008). · cites it 11× “{¶ 15} First, the basic logic of R.C. 5715.27 dictates our conclusion. The very essence of “exempting” property from taxation lies in relieving it from the levy and assessment of tax, not in forestalling the collection of taxes that have previously been levied.”
Gahanna-Jefferson Local Sch. Dist. Bd. of Edn. v. Zaino, 2001 Ohio 1335 (Ohio 2001). · cites it 47× “” R.C. 5715.27 {¶ 10} In contrast to R.C. 3735.”
Strongsville Bd. of Edn. v. Zaino, 2001 Ohio 1269 (Ohio 2001). · cites it 36× “] Taxation—Real property—Application for exemption—R.C. 5715.27, applied— Decisions of Board of Tax Appeals dismissing complaints objecting to application for exemption reasonable and lawful, when.”
Performing Arts Sch. of Metro. Toledo, Inc. v. Wilkins, 104 Ohio St. 3d 284 (Ohio 2004). · cites it 14× “The term “owner” is not defined for the purposes of R.C. 5715.27. *286 {¶ 10} In Grieser v. Huntington Natl.”
O'Keefe v. McClain (Slip Opinion), 2021 Ohio 2186 (Ohio 2021). · cites it 5× “Nothing in R.C. 5715.27 authorizes stripping property of its exempt status just because it no longer qualifies for an exemption it once qualified for, as long as that property currently qualifies for an exemption that is in effect.”
Pump House Ministries v. Levin, 2014 Ohio 1590 (Ohio Ct. App. 2014). · cites it 19× “The Court noted that “owner” was not defined for the purposes of R.C. 5715.27 but, affording the term “owner” its plain and ordinary meaning, “owner” as used in R.”
Columbus City Sch. Dist. Bd. of Educ. v. Wilkins, 802 N.E.2d 637 (Ohio 2004). · cites it 10× “The BOE contends that such notice is required under R.C. 5715.27. {¶ 17} R.C. 5715.27 is a general statute applicable both to applications for exemption and to complaints against existing exemptions.”
Princeton City Sch. Dist. Bd. of Educ. v. Zaino, 760 N.E.2d 375 (Ohio 2002). · cites it 3× “In this case, R.C. 5715.27(A) permits the owner of the property seeking exemption to “file an application with the tax commissioner * * * requesting that *74 such property be exempted from taxation and that unpaid taxes and penalties be remitted as provided in division (B) of…”
Show all 39 citing cases →
— Ohio Rev. Code § 5715.27(A) — 16 cases
Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
ShadoArt Prods., Inc. v. Testa (Slip Opinion), 2016 Ohio 511 (Ohio 2016). “{¶ 1} This real-property-tax exemption case turns on the relationship between R.C. 5715.27, which authorizes the filing of exemption applications and specifies who has standing to file one, and R.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
Pump House Ministries v. Levin, 2014 Ohio 1590 (Ohio Ct. App. 2014). “The Court noted that “owner” was not defined for the purposes of R.C. 5715.27 but, affording the term “owner” its plain and ordinary meaning, “owner” as used in R.”
Princeton City Sch. Dist. Bd. of Educ. v. Zaino, 760 N.E.2d 375 (Ohio 2002). “In this case, R.C. 5715.27(A) permits the owner of the property seeking exemption to “file an application with the tax commissioner * * * requesting that *74 such property be exempted from taxation and that unpaid taxes and penalties be remitted as provided in division (B) of…”
— Ohio Rev. Code § 5715.27(A)(1) — 4 cases
ShadoArt Prods., Inc. v. Testa (Slip Opinion), 2016 Ohio 511 (Ohio 2016). “{¶ 1} This real-property-tax exemption case turns on the relationship between R.C. 5715.27, which authorizes the filing of exemption applications and specifies who has standing to file one, and R.”
Wellington Square, L.L.C. v. Testa, 2012 Ohio 4981 (Ohio Ct. App. 2012).
Centerville v. Testa, 2014 Ohio 1972 (Ohio Ct. App. 2014).
Sightless Child. Club v. Montgomery Cty. Bd. of Revision, 2013 Ohio 3282 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 5715.27(B) — 8 cases
Cincinnati City Sch. Dist. Bd. of Edn. v. Testa (Slip Opinion), 2014 Ohio 4647 (Ohio 2014). “{¶ 1} This appeal involves appellee the city of Cincinnati’s application for exemption from real-property tax for property that constitutes part of the city’s convention center, the Duke Energy Center.”
Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
Columbus City Sch. Dist. Bd. of Educ. v. Wilkins, 802 N.E.2d 637 (Ohio 2004). “The BOE contends that such notice is required under R.C. 5715.27. {¶ 17} R.C. 5715.27 is a general statute applicable both to applications for exemption and to complaints against existing exemptions.”
Gahanna-Jefferson Local Sch. Dist. Bd. of Edn. v. Zaino, 2001 Ohio 1335 (Ohio 2001). “” R.C. 5715.27 {¶ 10} In contrast to R.C. 3735.”
— Ohio Rev. Code § 5715.27(B)(1) — 1 case
RiverSouth Auth. v. Harris, 2026 Ohio 2396 (Ohio 2026).
— Ohio Rev. Code § 5715.27(C) — 9 cases
Cincinnati City Sch. Dist. Bd. of Edn. v. Testa (Slip Opinion), 2014 Ohio 4647 (Ohio 2014). “{¶ 1} This appeal involves appellee the city of Cincinnati’s application for exemption from real-property tax for property that constitutes part of the city’s convention center, the Duke Energy Center.”
Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
Gahanna-Jefferson Local Sch. Dist. Bd. of Edn. v. Zaino, 2001 Ohio 1335 (Ohio 2001). “” R.C. 5715.27 {¶ 10} In contrast to R.C. 3735.”
Strongsville Bd. of Edn. v. Zaino, 2001 Ohio 1269 (Ohio 2001). “] Taxation—Real property—Application for exemption—R.C. 5715.27, applied— Decisions of Board of Tax Appeals dismissing complaints objecting to application for exemption reasonable and lawful, when.”
— Ohio Rev. Code § 5715.27(D) — 6 cases
Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
Gahanna-Jefferson Local Sch. Dist. Bd. of Edn. v. Zaino, 2001 Ohio 1335 (Ohio 2001). “” R.C. 5715.27 {¶ 10} In contrast to R.C. 3735.”
Cincinnati City Sch. Dist. Bd. of Edn. v. Testa (Slip Opinion), 2014 Ohio 4647 (Ohio 2014). “{¶ 1} This appeal involves appellee the city of Cincinnati’s application for exemption from real-property tax for property that constitutes part of the city’s convention center, the Duke Energy Center.”
Strongsville Bd. of Edn. v. Zaino, 2001 Ohio 1269 (Ohio 2001). “] Taxation—Real property—Application for exemption—R.C. 5715.27, applied— Decisions of Board of Tax Appeals dismissing complaints objecting to application for exemption reasonable and lawful, when.”
— Ohio Rev. Code § 5715.27(E) — 11 cases
Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
Gahanna-Jefferson Local Sch. Dist. Bd. of Edn. v. Zaino, 2001 Ohio 1335 (Ohio 2001). “” R.C. 5715.27 {¶ 10} In contrast to R.C. 3735.”
Strongsville Bd. of Edn. v. Zaino, 2001 Ohio 1269 (Ohio 2001). “] Taxation—Real property—Application for exemption—R.C. 5715.27, applied— Decisions of Board of Tax Appeals dismissing complaints objecting to application for exemption reasonable and lawful, when.”
O'Keefe v. McClain (Slip Opinion), 2021 Ohio 2186 (Ohio 2021). “Nothing in R.C. 5715.27 authorizes stripping property of its exempt status just because it no longer qualifies for an exemption it once qualified for, as long as that property currently qualifies for an exemption that is in effect.”
— Ohio Rev. Code § 5715.27(F) — 15 cases
City of Toledo v. Levin, 117 Ohio St. 3d 373 (Ohio 2008). “{¶ 15} First, the basic logic of R.C. 5715.27 dictates our conclusion. The very essence of “exempting” property from taxation lies in relieving it from the levy and assessment of tax, not in forestalling the collection of taxes that have previously been levied.”
Strongsville Bd. of Educ. v. Zaino, 751 N.E.2d 996 (Ohio 2001). “27(E) was added to R.C. 5715.27 in 1982 (Am.Sub.S.B. No. 262, 139 Ohio Laws, Part I, 711, 713).”
Bd. of Educ. v. Zaino, 754 N.E.2d 789 (Ohio 2001). “” R.C. 5715.27 In contrast to R.C. 3735.65 et seq.”
O'Keefe v. McClain (Slip Opinion), 2021 Ohio 2186 (Ohio 2021). “Nothing in R.C. 5715.27 authorizes stripping property of its exempt status just because it no longer qualifies for an exemption it once qualified for, as long as that property currently qualifies for an exemption that is in effect.”
Princeton City Sch. Dist. Bd. of Educ. v. Zaino, 760 N.E.2d 375 (Ohio 2002). “In this case, R.C. 5715.27(A) permits the owner of the property seeking exemption to “file an application with the tax commissioner * * * requesting that *74 such property be exempted from taxation and that unpaid taxes and penalties be remitted as provided in division (B) of…”
— Ohio Rev. Code § 5715.27(G) — 1 case
Cleveland Clinic Found. v. Levin, 898 N.E.2d 589 (Ohio 2008).
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