ch are completely inconsistent with and contrary to the theory upon which appellants proceeded below cannot be raised for the first time on review." Republic Steel Corp. v. Cuyahoga Cty. Bd. of Revision (1963), 175 Ohio St. 179, 192 N.E.2d 47, syllabus; see, also, State ex rel. Gutierrez v. Trumbull Cty. Bd. of Elec