Total Renal Care, Inc. v. Harris

Summary

The Ohio Supreme Court affirmed the Board of Tax Appeals’ denial of Total Renal Care’s refund claims, holding that the company’s gross receipts from dialysis services are sitused to Ohio because the benefit of those services is received in Ohio. The Court explained that the plain‑meaning of R.C. 5751.033(I) and the related administrative rule both require situsing based on the purchaser’s benefit location, and it found the Board’s decision reasonable.