Illinois Power Co. v. Mahin

Here is a question of statutory construction.

Illinois Power, a utility company, was notified by the Department of Revenue that additional taxes for the period July 1969 through May 1972, in the amount of *235,406.61, were owed. These were then paid under protest pursuant to statute (Ill. Rev. Stat. 1973, ch. 7, pars. 170 through 172a), and the utility thereafter instituted suit for refund and an injunction.

Under the Gas Revenue Tax Act and Public Utilities Revenue Act (Ill. Rev. Stat. 1973, ch. 120, pars. 467.16 through 481a), the utility is subject to a tax on its “gross receipts.” The…