taxes demanded of non residents of city

[Avenger]

A company ( I'll call "company A ")who had branches world wide chose to sell the factory I had been employed at for many years because they wanted out of manufacturing. A group of investers ("company B" )arranged to buy the building and is machinery along with the inventory.
Company B would then produce "company A's" products to thier specs as supplier.
Before "Company A" ,would agree to the sale they insisted that our Union agree to a new 5 year contract with "company B" that included large wage and benefit concessions.
As an insentive for us to agree to the concessions and the new contract with "company B" , "Company A" offered a one time "transition" bonus to current employees of "company A" if they fullfilled some requirements.
The requirements were
1. We must hire in to "company B" at time of transfer
2. We must continuously work for "company B" for one year.
It was "company A's" intent that by persuading the skilled workers to remain that "company B" would have the best chance at success as well as assure "company A" would receive quality products.
Because the receipt of this bonus hinged on our decision to hire in and then decide to continue working for "company B" for one full year we who are non- residents of the city did not file or report this "income" to the city in which the company is located.
After one year as promised,"company A" paid those whohad fulfilled the requirements, and it was reported as "non-employee compensation" on a 1099 form.
We reported and payed taxes to our own municipalities as well as the State and IRS.
In September the city in which the factory is located sent each of us who are non residents ,letters demanding we file and pay tax on this bonus.
We believe since "company A" was not our employer within the city and we received the bonus solely because we "decided or chose" to go to work at "company B" and that decission was made in our homes each day before going to work, that we do not owe the city we are not residents of tax on this bonus.
Thier tax code specifies for "non resident taxpayers" "there is imposed on all salaries,wages,commissions and other compensation earned or accrued,for work done or services rendered within the city,whether renumeration is recieved or earned directly or through an agent"
The letter sent to us in September did not include any information that a "board of review" was available if we did not agree we owed the city tax on this bonus. I went to the tax department and requested a copy of the tax ordinance. In that I found the board of review option. Ohio revised code states "When ever a tax administrator issues a decision regarding municipal income tax obligationt hat is subject to appeal as provided in this section or in an ordinance or regulation of the municipal corporation, the tax administrator shall notify the taxpayer in writting at the same time of the taxpayer's right to appeal the decision and of the manner in which the taxpayer may appeal the decision.
There were 91 letters sent out demanding payment and filing of forms. Not one person recieved any information about the right to appeal.
I did request a hearing and it was granted 45 1/2 days later. Since the board is made up of ,one person appointed by the mayor,one person appointed by the city councel and one appointed by those two, you can understand why they ruled against me.
My question is, based on the info provided who is correct and is not including the available appeal process by the city something that should be addressed? The board di not mention it in thier decision sent to me.

You can do an appeal normally if you missed the deadline and they had failed to notice you properly.

Do you want to appeal now still? Or was that hearing you mentioned the appeal?

[Avenger]

Yes I have excersied the Board of Review option and they ruled in favor of the city. This was not too surprizing since the board is made up of 3 people hand picked by the mayor and the city council.
I am thinking of continuing on to Common pleas. In essence what the ruling said was, since we worked for the company who paid the bonus and then the new company without loosing any days of work, and that both employers were inthe city and the same building and there is a supplier customer relationship between them, we owe the tax.
They never defined what we did within the city for the company that paid the bonus.
There are several of the 91 people who are involved that are willing to chip in for the costs. None of us or feel we owe the city tax but the city is relying on everyone just giving in and paying because it is not that much money.