DTCT, Inc. v. City of Chicago Department of Revenue

Justice McBride concurred in the judgment and opinion.

Presiding Justice Garcia dissented, with opinion.

OPINION

This consolidated appeal arises from three actions for administrative review of a tax assessment imposed by the City of Chicago department of revenue (Department) against a group of corporations under the employer’s expense tax (employer’s tax) (Chicago Municipal Code §3—20—030 (eff. July 1, 1995)). In each case, the assessment was based on the Department’s finding that, under the language of the tax ordinance, it could combine the employees of commonly owned though separately…