National School Bus Service, Inc. v. Department of Revenue

In this case we must decide whether rolling stock used occasionally in interstate commerce qualifies for exemption from the use tax. See 35 ILCS 105/1 et seq. (West 1992). The Department of Revenue (the Department) denied the exemption National School Bus Service sought, and the circuit court affirmed the Department’s ruling. National appeals. The Mid-West Truckers’ Association, Inc., and Illinois Movers’ and Warehousemen’s Association submitted a brief as amici curiae, supporting National.

The Interstate Commerce Commission issued a certificate granting National authority to operate as a…