Schmidt v. Department of Revenue

The instant appeal involves the issue of whether a taxpayer may seek administrative review of a final tax assessment after applying for and obtaining amnesty for such taxes under the Illinois Tax Delinquency Amnesty Act (Pub. Act 83—1428, eff. Oct. 1, 1984) (hereinafter the Amnesty Act).

In February 1983 the plaintiff, Wanda Schmidt, d/b/a Le Don’s (taxpayer), received a notice of tax liability from the defendant, Illinois Department of Revenue (Department), with regard to retailers’ occupation taxes allegedly owed by the taxpayer for the years 1975 through 1981. The taxpayer paid the taxes…