concurring. While I am heartened that the majority herein does not attempt to “squeeze” an exception out of R.C. 5739.01 for the taxpayer in this case, it is unfortunate that the majority failed to exercise similar restraint in Procter & Gamble Co. v. Lindley (1985), 17 Ohio St. 3d 71, where it chose instead to “squeeze” an exception out of R.C. 5739.01(E)(1) for the taxpayer therein.