Phoenix Bond & Indemnity Co. v. Pappas

This litigation challenges a rule promulgated by the Cook County collector regarding the acceptance of penalty bids at the County’s annual tax sale. On cross-motions for summary judgment, the circuit court of Cook County found the rule invalid and permanently enjoined its enforcement. The appellate court reversed. 309 Ill. App. 3d 779. We granted leave to appeal (177 Ill. 2d R. 315) and now affirm the appellate court’s judgment.

The procedures governing tax sales are set forth in article 21, division 4, of the Property Tax Code (35 ILCS 200/21 — 190 et seq. (West 1996)). That statute provides…