Rogy's New Generation, Inc. v. Department of Revenue

This is an appeal from a final decision of the circuit court affirming the decision of the Illinois Department of Revenue (DOR) to deny the application for tax-exempt status to Rogy’s New Generation, Inc., and to revoke the tax-exempt status of Rogy’s Gingerbread House, Inc., and Rogy’s Child Care Center, Inc. (collectively Rogy). There are three issues raised in this appeal: (1) whether Rogy’s facilities qualify as statutorily defined entities organized exclusively for educational purposes; (2) whether the DOR’s denial and revocation of Rogy’s tax-exempt status violates Rogy’s due process…