People v. International Business MacHines Corp.

The State brought an action against defendant, International Business Machines Corporation (IBM), for nonpayment of $2,595,394.86 in personal property taxes pursuant to the Cook County assessor’s 1976 assessment. The circuit court of Cook County found constructive fraud in the assessor’s 1976 personal property assessment and entered judgment in favor of IBM. The appellate court affirmed (93 Ill. App. 3d 564), and we granted the State leave to appeal.

The issue is whether the trial court’s finding of constructive fraud in IBM’s 1976 personal property tax assessment is supported by clear and…