Chicago & Illinois Midland Railway Co. v. Department of Revenue

Plaintiff, Chicago & Illinois Midland Railway Co. (the Railway), brought this action in the circuit court of Cook County against the Department of Revenue, Robert Allphin, Director of Revenue, and Alan Dixon, Treasurer of the State of Illinois, pursuant to “An Act in relation to the payment and disposition of moneys received by officers and employees of the State of Illinois by virtue of their office or employment” (Ill. Rev. Stat. 1973, ch. 127, pars. 170 through 176a (hereinafter Protest Act)). The Railway sought a refund of Illinois use tax (Ill. Rev. Stat. 1973, ch. 120, pars. 439.1…