County of Boone v. Department of Revenue

Plaintiffs, Boone County and the Boone County Board of Review (Board), appeal from an order of the circuit court which affirmed an administrative decision finding that the Belvidere Oasis, property owned by defendant, the Illinois State Toll Highway Authority (Tollway Authority), was exempt from real estate taxes for 1985. Plaintiffs raise one issue on appeal: whether the trial court erred in determining that, under the 1985 version of the Revenue Act of 1939 (Revenue Act) (Ill. Rev. Stat. 1985, ch. 120, par. 482 et seq.), only property which is leased is subject to taxation.

On March 26,…