Central Illinois Light Co. v. Department of Revenue

PRESIDING JUSTICE McCULLOUGH

delivered the opinion of the court:

Plaintiff Freeman United Coal Mining Company (Freeman), referred to collectively with Central Illinois Light Company (CILCO) as Taxpayers, appeals from an order of the circuit court of Sangamon County affirming on administrative review a decision of the Illinois Department of Revenue (Department). The issues on review are whether (1) Freeman is entitled to a credit or refund on the basis that the coal sold by Freeman to CILCO was exempt under section la of the Illinois Retailers’ Occupation Tax Act (ROTA) (35 ILCS 120/la (West…