Hormel Foods Corp. v. Zehnder

Plaintiffs Hormel Foods Corporation and one of its subsidiaries, Jennie-0 Foods, Inc. (collectively Taxpayers), appeal an order of the circuit court affirming a decision of the Director of the Illinois Department of "Revenue (Director). The Director found that, for purposes of the Illinois Income Tax Act (Tax Act) (Ill. Rev. Stat. 1981, ch. 120, par. 1 — 101 et seq. (now 35 ILCS 5/101 et seq. (West 1998))), Taxpayers were members of a “unitary business group” for the years 1991, 1992, and 1993, as defined in section 1501(a)(27) of the Tax Act (35 ILCS 5/1501(a)(27) (West 1998)) and issued…