Humphrey Cadillac & Olds, Inc. v. Department of Revenue

The Department of Revenue (hereafter “the Department”) served Humphrey Cadillac and Olds, Inc. (hereafter “the Taxpayer”) with a notice of tax liability for use tax alleged to be owing upon automobiles held by the Taxpayer in what is termed a “rental” account. The assessment, including the penalty and interest, was in the amount of *11,869.30, and covered the period from July of 1972 through May of 1975. After an evidentiary hearing before one of the Department’s hearing officers, the assessment was confirmed and the Taxpayer filed a complaint under the Administrative Review Act (Ill. Rev. Stat.…