Ohio Supreme Court July 11, 1984, No. 83-1979 (Condee v. Lindley)

Per Curiam.

The primary and determinative issue before the court is whether the Tax Commissioner’s policy (allocating thirty percent of situsable property value to the non-situsable property value category when compiling and issuing certificates of tax valuation on public utility property) is an improperly adopted rule and therefore invalid.