Cook County Board of Review v. Property Tax Appeal Board

We address a Cook County Board of Review (the Board) appeal challenging a decision by the Illinois Property Tax Appeal Board (PTAB). The main question we consider is whether PTAB has the authority to expand the scope of a taxpayer’s appeal to include issues never raised by the taxpayer before the Cook County Board of Review. In this case, PTAB ruled that responsive pleadings of the Board on appeal raised issues PTAB was empowered to address. We conclude that, under the Administrative Review Law (735 ILCS 5/3 — 101 et seq. (West 2000)) and PTAB’s own rules, the scope of PTAB’s review and the…