Shell Oil Co. v. Department of Revenue

The Department of Revenue (Department) appeals the trial court’s reversal, on administrative review, of its decision that certain equipment installed by plaintiff, Shell Oil Company, at its Wood River, Illinois, refinery, is not tax exempt since the equipment does not have pollution control as its “primary purpose” within the meaning of section 2a of the Use Tax Act (Ill. Rev. Stat. 1979, ch. 120, par. 439.2a). We affirm in part and reverse in part.

The present controversy began on December 4, 1979, when the Department issued plaintiff a notice of tax liability for alleged deficiencies in…