Chicago Title & Trust Co. v. Department of Revenue

Defendant, the Illinois Department of Revenue, appeals from a judgment of the circuit court of Cook County which reversed the defendant’s determination that plaintiff, Chicago Title & Trust Company, owed a deficiency for Illinois taxes for the years 1971 through 1976.

From 1971 through 1976 plaintiff incurred operating losses. Consequently, plaintiff’s taxable income as reported on line 30 of its United States corporation income tax return, Form 1120, reflected negative income. When computing its Illinois base income, plaintiff then entered as its starting figure its Federal taxable income,…