Moody's Investors Service, Inc. v. Department of Revenue

PRESIDING JUSTICE WEBBER

delivered the opinion of the court:

The defendants (Department) appeal from an order of the circuit court of Sangamon County, sitting in administrative review, which reversed a determination by the Department that the sales of plaintiff’s (Moody) publications were subject to taxation pursuant to the provisions of the Retailers’ Occupation Tax Act (Ill. Rev. Stat. 1979, ch. 120, par. 440 et seq.) (ROTA) and the Use Tax Act (Ill. Rev. Stat. 1979, ch. 120, par. 439.1 et seq.).

Before considering the merits of the appeal, we must first thread our way through an extremely…