Legal Opinion
Chicago SMSA Ltd. Partnership v. Department of Revenue
Appellate Court of Illinois
Decided July 29, 1999No. 1-98-3565, 1-99-1114 consPublishedCited by 3 opinions
1Opinion of the CourtJustice Wolfson
The taxpayers in this case are cellular telephone service providers. They pose a $1.4 million question: do the words “exclude from active regulatory oversight” in one statute have the same meaning as “not regulated” in another? If they do, the taxpayers do not have to pay the invested capital tax assessed by the Illinois Department of Revenue.
We conclude the phrases in the two statutes were not intended to mean the same thing. For that and other reasons, we affirm the trial court’s orders requiring the taxpayers to pay the Department of Revenue’s assessments.
FACTS
Chicago SMSA Limited…
2Cases cited16 opinions
- International Brotherhood of Teamsters v. United StatesSupreme Court of the United States · 1977
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- United States v. PriceSupreme Court of the United States · 1960
- Kraft, Inc. v. EdgarIllinois Supreme Court · 1990
- Texaco-Cities Service Pipeline Co. v. McGawIllinois Supreme Court · 1998
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3Cited by3 opinions
- Board of Education of Park Forest Heights School District No. 163. v. State Teacher Certification BoardAppellate Court of Illinois · 2006
- Mohica v. CvejinAppellate Court of Illinois · 2013
- Southwestern Bell Mobile Systems, Inc. v. Department of RevenueAppellate Court of Illinois · 2000