The Ohio Department of Taxation may issue an ‘opinion of the Tax Commissioner‘ on how a transaction or activity will be taxed, for any tax type, on a prospective basis. The Department is bound by the opinions as to the requesting taxpayers unless and until the opinion is revoked or expires, or a material change occurs in the applicable facts or law. Taxpayers, however, are not similarly bound. Although the Department does publish some redacted opinions, published opinions provide guidance only and may not be cited as precedent or relied on by other taxpayers. An opinion of the Tax Commissioner is not a final determination of the Commissioner and may not be appealed to the Board of Tax Appeals.