JI Aviation, Inc. v. Department of Revenue

This is an action for administrative review of the Illinois Department of Revenue’s (the Department) determination that plaintiff JI Aviation, Inc. (JI Aviation), owed state use tax on its purchase of a corporate jet. The circuit court reversed the Department and subsequently denied reconsideration. The Department now appeals, and no issues are raised on the pleadings. For the reasons that follow, we affirm.

The following undisputed facts have been set forth in the fully stipulated factual record. On May 25, 1994, JI Aviation and Richland Development Corp. entered into an “Aircraft Acquisition…