Airco Industrial Gas Division v. Department of Revenue

PRESIDING JUSTICE GREEN

delivered the opinion of the court:

On April 20, 1988, defendant Illinois Department of Revenue (Department) issued plaintiff Aireo Industrial Gas Division, the BOG Group, Inc., a notice of tax liability assessing a deficiency which included $227,192 plus penalties and interest thereon, under the Retailers’ Occupation Tax Act (Act) (Ill. Rev. Stat. 1989, ch. 120, par. 440 et seq.). The assessment covered a period from January 1, 1982, to December 31, 1986. On June 20, 1990, plaintiff filed a complaint in the circuit court of Sangamon County for administrative review…