Tri-America Oil Co. v. Department of Revenue

Plaintiff filed a complaint for administrative review in the circuit court seeking to set aside an assessment of taxes judged by defendants as due under the Retailers’ Occupation Tax Act (Ill. Rev. Stat. 1981, ch. 120, par. 440 et seq.) and the Municipal Retailers’ Occupation Tax Act (Ill. Rev. Stat. 1981, ch. 24, par. 8 — 11—1 et seq.) (hereinafter both referred to as the Act). The circuit court reversed the administrative decision, and this appeal follows.

Plaintiff is a retail and wholesale seller of gasoline. Defendants audited plaintiff for the period of January 1975 to December 1977 and…