United Technical Corp. v. Department of Revenue

The Illinois Department of Revenue (Department) appeals from an adverse decision on administrative review in an action by which it sought to collect the Retailers’ Occupation Tax (Ill. Rev. Stat. 1977, ch. 120, par. 440 et seq.) (ROT) and Municipal Retailers’ Occupation Tax (Ill. Rev. Stat. 1977, ch. 24, par. 8 — 11—1) (MROT) 1 allegedly due from United Technical Corporation (United). The sole issue raised on appeal is whether partial prepayment of the purchase price of tangible personal property is taxable at the time of receipt thereof by the seller.

United is a holding company whose…