Partners Analyze Sale-Leaseback Tax Disputes in Crain’s Cleveland Business
SDG Legal partners Robert “Kip” Danzinger and Elizabeth A. Taylor recently published an analysis of Ohio sale-leaseback property tax disputes in Crain’s Cleveland Business.
The Sale-Leaseback Tax Challenge
A sale-leaseback transaction occurs when an owner sells property to a buyer and contemporaneously leases it back. While this provides immediate cash and operational flexibility, it creates property tax complications when school districts attempt to use the sale price as justification for assessment increases.
Key Issue: Are Sale-Leasebacks Arm’s-Length Transactions?
The consideration paid in sale-leaseback transactions typically relates to financing arrangements rather than actual fair market value. This distinction is critical under Ohio property tax law, where “recent arm’s length sale price” is deemed the best evidence of value.
Recent BTA Ruling
In AG Parma, LLC v. Cuyahoga Cty. Bd. of Revision (BTA No. 2024-1414, June 23, 2025), the Ohio Board of Tax Appeals held that sale-leaseback transactions are not arm’s-length transactions and therefore cannot form the basis for valid school district increase complaints.
Impact of H.B. 126
The 2022 legislation already limited school districts’ ability to file increase complaints. Combined with the BTA’s sale-leaseback ruling, property owners now have stronger grounds to challenge inappropriate assessment increases based on these transactions.
Other Valuation Conflicts
Sale-leasebacks are one of several transaction types creating disputes between taxpayers and school districts, including:
- Net-leased property sales
- Auction sales
- Receivership sales
Read the Full Analysis
For complete details on sale-leaseback tax implications and the recent BTA decision:
Sale/Leasebacks: The Conflict Between Taxpayers and School Districts
Published in Crain’s Cleveland Business
October 27, 2025
By Robert “Kip” Danzinger, Esq. and Elizabeth A. Taylor, Esq.
About the Authors
Robert “Kip” Danzinger is a partner at Sleggs, Danzinger & Gill specializing in Ohio property tax law and complex valuation disputes.
Elizabeth A. Taylor is an associate attorney at SDG Legal representing commercial property owners in assessment appeals and litigation.
March 31, 2026 Deadline
The deadline to file property tax complaints for tax year 2025 is March 31, 2026. If you acquired property through a sale-leaseback or other complex transaction, contact our office for a complimentary assessment review.
Call (216) 771-8990 or contact our attorneys →