Ohio Revised Code

Ohio Rev. Code § 5739.16 (2026)

Four-year limitation for assessments - exceptions

✓ current as of May 2026
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(A) Except as otherwise provided in this section, no assessment shall be made or issued against a vendor or consumer for any tax imposed by or pursuant to section 5739.02, 5739.021, 5739.023, 5739.026, or 5739.10 of the Revised Code more than four years after the return date for the period in which the sale or purchase was made, or more than four years after the return for such period is filed, whichever is later. A consumer who provides a fully completed exemption certificate pursuant to division (B) of section 5739.03 of the Revised Code may be assessed any tax imposed by or pursuant to section 5739.02, 5739.021, 5739.023, or 5739.026 of the Revised Code that results from denial of the claimed exemption within the later of a period otherwise allowed by this section or one year after the date the certificate was provided. This division does not bar an assessment:

(1) When the tax commissioner has substantial evidence of amounts of taxes collected by a vendor from consumers on retail sales, which were not returned to the state;

(2) When the vendor assessed failed to file a return as required by section 5739.12 of the Revised Code;

(3) When the vendor or consumer and the commissioner waive in writing the time limitation.

(B) No assessment shall be made or issued against a vendor or consumer for any tax imposed by or pursuant to section 5739.02, 5739.021, 5739.023, 5739.026, or 5739.10 of the Revised Code for any period during which there was in full force and effect a rule of the tax commissioner under or by virtue of which the collection or payment of any such tax was not required. This division does not bar an assessment when the tax commissioner has substantial evidence of amounts of taxes collected by a vendor from consumers on retail sales which were not returned to the state.

(C) No assessment shall be made or issued against a person for any tax imposed pursuant to section 5739.101 of the Revised Code more than four years after the return date for the period in which the tax is imposed on the person's gross receipts, or more than four years after the return for such period is filed, whichever is later. This division does not bar an assessment when the person assessed failed to file a return as required under section 5739.102 of the Revised Code, or when the person and the commissioner waive in writing the time limitation.

Notes of Decisions
Cited in 11 cases, 1988–2016 · leading case: Youngstown Sheet & Tube Co. v. Lindley, 527 N.E.2d 828 (Ohio 1988).
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Youngstown Sheet & Tube Co. v. Lindley, 527 N.E.2d 828 (Ohio 1988). · cites it 8× “Code 5703-9-21[J]) and R.C. 5739.16(B). Youngstown admits that the rule improperly interpreted the statute then in effect, but argues that R.”
Ceccarelli v. Levin, 2010 Ohio 5681 (Ohio 2010). · cites it 4× “By contrast, the statute of limitation for sales-tax assessments is set forth in R.C. 5739.16, which is an entirely different section from the section that authorizes the tax commissioner to make assessments (R.”
Lyden Co. v. Tracy, 666 N.E.2d 556 (Ohio 1996). · cites it 17× “We believe that R.C. 5739.16(5) is similar, barring assessments by the commissioner contrary to official statements of tax policy, based on a determination of the General Assembly that taxpayers should be entitled to rely on official statements and policies issued by the…”
Internatl. Paper Co. v. Testa (Slip Opinion), 2016 Ohio 7454 (Ohio 2016). · cites it 6× “{¶ 42} The General Assembly has twice amended R.C. 5739.16—the statute at issue in Carstab—since our 1988 decision.”
HealthSouth Corp. v. Levin, 903 N.E.2d 1179 (Ohio 2009). “2d 556 , addressed sales-tax issues under R.C. 5739.16(B). Both are inapposite, because they merely construe and apply statutory language to the circumstances of the particular case before the court.”
G & J Pepsi Cola Bottling, Inc. v. Limbach, 548 N.E.2d 936 (Ohio 1990). “Code 5703-9-21(E) and R.C. 5739.16(B), as the statutory “packaging exemption” in R.”
Carstab Corp. v. Limbach, 532 N.E.2d 102 (Ohio 1988). · cites it 5× “The sole question presented is whether an assessment is barred if it is not received by a taxpayer within the time limits provided in R.C. 5739.16 and 5741.16. For the reasons stated below, we hold that it is not so barred and affirm the BTA.”
Bowshier v. Limbach, 556 N.E.2d 463 (Ohio 1990). · cites it 10× “The commissioner argues that R.C. 5739.16 bars only assessments made against vendors or consumers and not those against corporate officers assessed personally under R.”
Stines v. Limbach, 573 N.E.2d 131 (Ohio Ct. App. 1988). · cites it 2× “Such application for refund shall be filed with the commissioner within four years from the date of the illegal or erroneous payment of the tax except where the vendor or consumer waives the time limitation under division (A)(3) of section 5739.16 of the Revised Code, in which…”
Lyden Co. v. Tracy, 1996 Ohio 112 (Ohio 1996). · cites it 20× “(R.C. 5739.16[B], construed; Youngstown Sheet & Tube Co.”
ARGA Co. v. Tracy, 666 N.E.2d 1076 (Ohio 1996). · cites it 2× “2d 556 , decided this date, we held: “For purposes of R.C. 5739.16(B), an administrative rule adopted by the Tax Commissioner remains ‘in full force and effect’ until the commissioner rescinds it or a court specifically declares it invalid as being contrary to statute or…”
— Ohio Rev. Code § 5739.16(5) — 1 case
Lyden Co. v. Tracy, 666 N.E.2d 556 (Ohio 1996). “We believe that R.C. 5739.16(5) is similar, barring assessments by the commissioner contrary to official statements of tax policy, based on a determination of the General Assembly that taxpayers should be entitled to rely on official statements and policies issued by the…”
— Ohio Rev. Code § 5739.16(A) — 6 cases
Ceccarelli v. Levin, 2010 Ohio 5681 (Ohio 2010). “By contrast, the statute of limitation for sales-tax assessments is set forth in R.C. 5739.16, which is an entirely different section from the section that authorizes the tax commissioner to make assessments (R.”
Internatl. Paper Co. v. Testa (Slip Opinion), 2016 Ohio 7454 (Ohio 2016). “{¶ 42} The General Assembly has twice amended R.C. 5739.16—the statute at issue in Carstab—since our 1988 decision.”
Lyden Co. v. Tracy, 666 N.E.2d 556 (Ohio 1996). “We believe that R.C. 5739.16(5) is similar, barring assessments by the commissioner contrary to official statements of tax policy, based on a determination of the General Assembly that taxpayers should be entitled to rely on official statements and policies issued by the…”
Carstab Corp. v. Limbach, 532 N.E.2d 102 (Ohio 1988). “The sole question presented is whether an assessment is barred if it is not received by a taxpayer within the time limits provided in R.C. 5739.16 and 5741.16. For the reasons stated below, we hold that it is not so barred and affirm the BTA.”
Bowshier v. Limbach, 556 N.E.2d 463 (Ohio 1990). “The commissioner argues that R.C. 5739.16 bars only assessments made against vendors or consumers and not those against corporate officers assessed personally under R.”
— Ohio Rev. Code § 5739.16(B) — 6 cases
Youngstown Sheet & Tube Co. v. Lindley, 527 N.E.2d 828 (Ohio 1988). “Code 5703-9-21[J]) and R.C. 5739.16(B). Youngstown admits that the rule improperly interpreted the statute then in effect, but argues that R.”
Lyden Co. v. Tracy, 666 N.E.2d 556 (Ohio 1996). “We believe that R.C. 5739.16(5) is similar, barring assessments by the commissioner contrary to official statements of tax policy, based on a determination of the General Assembly that taxpayers should be entitled to rely on official statements and policies issued by the…”
HealthSouth Corp. v. Levin, 903 N.E.2d 1179 (Ohio 2009). “2d 556 , addressed sales-tax issues under R.C. 5739.16(B). Both are inapposite, because they merely construe and apply statutory language to the circumstances of the particular case before the court.”
G & J Pepsi Cola Bottling, Inc. v. Limbach, 548 N.E.2d 936 (Ohio 1990). “Code 5703-9-21(E) and R.C. 5739.16(B), as the statutory “packaging exemption” in R.”
Lyden Co. v. Tracy, 1996 Ohio 112 (Ohio 1996). “(R.C. 5739.16[B], construed; Youngstown Sheet & Tube Co.”
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