As Introduced
136th General Assembly
Regular Session H. B. No. 124
2025-2026
Representatives Thomas, D., Hall, T.
Cosponsors: Representatives Bird, Daniels, Gross, Lear, Miller, K., Stephens
A B I L L
To amend sections 5715.012, 5715.251, and 5715.26
of the Revised Code to modify the process for
making property tax sales-assessment ratio
studies.
BE IT ENACTED BY THE GENERAL ASSEMBLY OF THE STATE OF OHIO:
Section 1. That sections 5715.012, 5715.251, and 5715.26
of the Revised Code be amended to read as follows:
Sec. 5715.012. The tax commissioner shall make sales-
assessment ratio studies of sales and assessments of real
property for the purpose of determining the common level of
assessment of real property within the counties pursuant to
section 5715.19 of the Revised Code and for the purpose of
equalization. Such studies shall be based solely on a
representative sampling of sales provided to the commissioner by
the county auditor. That sample shall include only open market
arms' length sales occurring during the three years prior to the
tax year to which the sample is applied of open market arms'
length sales by between a willing seller to a willing buyer for
a current like use within the class or classes of real property
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As Introduced
sampled by the board. Where there are not sufficient arms'
length sales to constitute a representative sampling for such
studies within a class, the commissioner auditor may also
conduct appraisals of real property in that class, which shall
be a part of such studies.
Such studies and other information of the commissioner may
be used by the commissioner as guidelines, where applicable, in
the equalization of a class or classes of real property. Such
studies or other information of the commissioner shall not be
applied by the commissioner on a taxing district, countywide, or
statewide basis for the purpose of equalization unless the
commissioner auditor first finds there are sufficient arms'
length sales for a like use included in the sample in a class,
or arms' length sales and appraisals conducted by the
commissioner auditor for a like use included in the sample in a
class, to provide an indication that said sales or sales and
appraisals in the class are representative of all parcels in the
class.
In addition, the commissioner shall make other studies of
the value of real property within the counties which may be used
as guidelines, where applicable, in the equalization of a class
or classes of real property.
Sec. 5715.251. The county auditor may appeal (A) The
following appeals may be taken to the board of tax appeals :
(1) A county auditor may appeal any determination of
change in the abstract of real property of a taxing district in
the auditor's county that is made by the tax commissioner under
section 5715.24 of the Revised Code.
(2) The commissioner may appeal an auditor's determination
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of the sales included in the representative sampling of sales
required to be used by the commissioner in making sales-
assessment ratio studies under section 5715.012 of the Revised
Code.
The (B) An appeal filed under division (A) of this section
shall be taken within thirty days after receipt of the statement
by the county auditor of the commissioner's determination by the
filing by the county auditor of or after the commissioner's
receipt of the representative sample, as applicable. For an
appeal under division (A)(1) of this section, the commissioner
shall be made appellee, and for an appeal under division (A)(2)
of this section, the county auditor shall be made appellee. The
appellant shall file a notice of appeal with the board and the
commissionerappellee. Such notice of appeal shall set forth the
determination of the commissioner or the auditor's
representative sample appealed from, as applicable, and the
errors therein complained of. Proof of the filing of such notice
with the commissioner appellee shall be filed with the board.
The board shall have exclusive jurisdiction of the appeal.
In all such appeals the commissioner shall be made
appellee. Unless waived, notice of the appeal shall be served
upon the commissioner appellee by certified mail. The
prosecuting attorney shall represent the county auditor in such
an appeal.
The (C) For an appeal under division (A)(1) of this
section, the commissioner, upon written demand filed by the
county auditor, shall within thirty days after the filing of
such demand file with the board a certified transcript of the
record of the commissioner's proceedings pertaining to the
determination complained of and the evidence the commissioner
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considered in making such determination. For an appeal under
division (A)(2) of this section, the auditor, upon written
demand filed by the commissioner, shall file with the board any
evidence the auditor considered in determining the contents of
the representative sampling of sales. The board shall notify the
auditor of the deadline, determined by the board, by which the
auditor shall file such evidence.
If upon hearing and consideration of such record and
evidence the board decides that the determination or sample
appealed from is reasonable and lawful, it shall affirm the
same, but if the board decides that such determination or sample
is unreasonable or unlawful, the board shall reverse and vacate
the determination or modify it shall modify the determination or
sample and enter a final order in accordance with such
modification.
The secretary of the board shall send the order of the
board to the county auditor and to the commissioner, and they
shall take such action in connection therewith as is required to
give effect to the order of the board. At the request of the
county auditor, the board of tax appeal's order shall be sent by
certified mail at the county auditor's expense.
Sec. 5715.26. (A)(1) Upon receiving the statement required
by section 5715.25 of the Revised Code, the county auditor shall
forthwith add to or deduct from each tract, lot, or parcel of
real property or class of real property the required percentage
or amount of the valuation thereof, adding or deducting any sum
less than five dollars so that the value of any separate tract,
lot, or parcel of real property shall be ten dollars or some
multiple thereof.
(2) After making the additions or deductions required by
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this section, the auditor shall transmit to the tax commissioner
the appropriate adjusted abstract of the real property of each
taxing district in the auditor's county in which an adjustment
was required.
(3) If the commissioner increases or decreases the
aggregate value of the real property or any class thereof in any
county or taxing district thereof and does not receive within
ninety days thereafter an adjusted abstract conforming to its
statement for such county or taxing district therein If an
auditor fails to comply with division (A)(2) of this section
within ninety days after either the auditor receives the
statement required by section 5715.25 of the Revised Code or the
board of tax appeals enters a final order regarding the appeal
of a commissioner determination , the commissioner shall withhold
from such county or taxing district therein fifty per cent of
its share in the distribution of state revenues to local
governments pursuant to sections 5747.50 to 5747.55 of the
Revised Code and shall direct the department of education and
workforce to withhold therefrom fifty per cent of state revenues
to school districts pursuant to Chapter 3317. of the Revised
Code. The commissioner shall withhold the distribution of such
funds until such county auditor has complied with this division,
and the department shall withhold the distribution of such funds
until the commissioner has notified the department that such
county auditor has complied with this division.
(B)(1) If the commissioner's determination is appealed an
appeal is filed under section 5715.251 of the Revised Code, the
county auditor, treasurer, and all other officers shall
forthwith proceed with the levy and collection of the current
year's taxes in the manner prescribed by law. The In the case of
an appeal filed under division (A)(1) of that section, the taxes
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shall be determined and collected as if the commissioner had
determined under section 5715.24 of the Revised Code that the
real property and the various classes thereof in the county as
shown in the auditor's abstract were assessed for taxation and
the true and agricultural use values were recorded on the
agricultural land tax list as required by law. In the case of an
appeal filed under division (A)(2) of that section, the taxes
shall be determined and collected as if the commissioner had
determined any change in the abstract of real property of a
taxing district under section 5715.24 of the Revised Code by
using the representative sampling of sales provided by the
county auditor without adjustment.
(2) If as a result of the appeal to the board it is
finally determined either that adjustments are required to an
auditor's representative sampling of sales, that all real
property and the various classes thereof have not been assessed
as required by law, or that the values set forth in the
agricultural land tax list do not correctly reflect the true and
agricultural use values of the lands contained therein, the
county auditor shall forthwith add to or deduct from each tract,
lot, or parcel of real property or class of real property the
required percentage or amount of the valuation in accordance
with the order of the board or judgment of the court to which
the board's order was appealed, and the taxes on each tract,
lot, or parcel and the percentages required by section 319.301
of the Revised Code shall be recomputed using the valuation as
finally determined. The order or judgment making the final
determination shall prescribe the time and manner for
collecting, crediting, or refunding the resultant increases or
decreases in taxes.
Section 2. That existing sections 5715.012, 5715.251, and
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5715.26 of the Revised Code are hereby repealed.
Section 3. The amendment by this act of sections 5715.012,
5715.251, and 5715.26 of the Revised Code applies to tax year
2025 and every tax year thereafter.
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