dissenting.
{¶ 35} I believe that a remand to the Tax Commissioner is appropriate in light of the intervening case of Cincinnati Bell Tel. v. Zaino (June 10, 2005), BTA Nos. 2003-K-765 and 2003-K-1612, which rejected a valuation study similar to that upon which Ohio Bell relied, instead allowing an appraisal of unit value.
{¶ 36} I also believe that Ohio Bell’s appeal provided sufficient notice of the claimed errors to establish jurisdiction and that the valuation study and appraisal went to the method of proof and the evidence presented, not to jurisdiction. The BTA, as the trier of fact, accepted the evidence, pursuant to the method it had already determined acceptable in Cincinnati Bell.
{¶ 37} Therefore, I would defer to the expertise of the BTA and would affirm its judgment of the value of Ohio Bell’s personal property as $1,702,157,675.