The opinion
O’Donnell, J.,
dissenting.
{¶ 42} Respectfully, I dissent.
{¶ 43} In my view, our decision in Dialysis Clinic, Inc. v. Levin, 127 Ohio St.3d 215 , 2010-Ohio-5071 , 938 N.E.2d 329 , is a controlling precedent as argued by the tax commissioner, and on that basis I would reverse the decision of the Board of Tax Appeals.
Kennedy, J., concurs in the foregoing opinion.