Total Renal Care, Inc. v. Harris

Summary

The Ohio Supreme Court affirmed the Board of Tax Appeals, holding that Total Renal Care’s gross receipts from dialysis services are sitused in Ohio because the benefit of the service is received by patients in Ohio. The court reasoned that the plain language of R.C. 5751.033(I) and the applicable administrative rule require situsing based on the purchaser’s location, and rejected the appellant’s argument that ancillary laboratory and administrative functions create a separate situs.