On remand from the Ohio Supreme Court, the Ohio Board of Tax Appeals (BTA) applied the true object test to determine whether charges paid by Cincinnati Federal Savings & Loan (Cincinnati Federal) to Fiserv constituted taxable automatic data processing (ADP) and electric information services (EIS), or nontaxable professional services. The Ohio Supreme Court had previously affirmed the BTA’s conclusion that Cincinnati Federal failed to prove it purchased nontaxable accounting services and directed the BTA to conduct a true object analysis.
Fiserv provided Cincinnati Federal with live access to an automated general ledger that tracked all transactional activity in real time. The system was fully automated and self‑correcting, with no cognitive review or analysis by Fiserv employees. Cincinnati Federal sought a refund of sales tax, arguing the true object of the transactions was to obtain professional services. The BTA rejected this position, concluding that the true object of the transaction was to obtain ADP and EIS.