holding that the phrase “public institution of learning” in a tax statute may encompass more than “a college or academy in the traditional sense,” but that any such institution must have “a teacher-student character”; therefore, the term could not be applied to an institution that merely summarized others’ research and sold the summaries to willing buyers
How later courts described this case
- holding that the phrase “public institution of learning” in a tax statute may encompass more than “a college or academy in the traditional sense,” but that any such institution must have “a teacher-student character”; therefore, the term could not be applied to an institution that merely summarized others’ research and sold the summaries to willing buyers
Written by the judges who cited it.
The opinion
Paul W. Brown, J.,
dissenting. The decision of the Board of Tax Appeals is both reasonable and lawful under R. C. 5709.07, 5709.12 and 5709.121.