Did Illinois Hotel Operators' Occupation Tax apply when a condominium resident rented a second bedroom through an online platform?

Plain-English summary

A resident lived in a two-bedroom condominium and rented the second bedroom through an online accommodations platform. Guests booked through the platform, stayed for less than 30 days, and paid the resident. The room contained a sofa rather than a bed, and the host screened prospective guests through the platform's membership system.

IDOR ruled that the payments were subject to Illinois Hotel Operators' Occupation Tax. The room provided living quarters, so the consideration was "rent" for occupancy. The lack of a bed was not important.

The platform's registration and screening features also did not make the room private-club lodging. IDOR viewed the platform as facilitating a rental that the host chose to accept. Screening prospective renters did not change the conclusion that the accommodation was available to the public for purposes of the tax.

What this means for you

A short-term rental can fall within the hotel tax even when it is one bedroom inside the host's own condominium, lacks a traditional hotel front desk, and is booked through a members-only online platform. IDOR focused on paid occupancy for living quarters and stays under 30 days.

This PLR states that it ceased to bind IDOR on January 13, 2026, ten years after the letter, or earlier if relevant law, rules, case law, or facts changed.

Common questions

Did the room need a bed? No.

Did platform membership make the rental private-club lodging? No, on these facts.

Who made the taxable rental? IDOR treated the resident host as renting the room; the platform facilitated the transaction.

Citations and references

• 35 ILCS 145/2(1), (3), and (6).
• 86 Ill. Adm. Code 480.101(b)(2) and (b)(3).
• 2 Ill. Adm. Code 1200.110(e).

Source

• Landing page: https://taxarchive.illinois.gov/research/legal/letter-rulings/sales-tax/2016.html
• Original PDF: https://tax.illinois.gov/content/dam/soi/en/web/taxarchive/research/legal/letter-rulings/sales-tax/2016/st-16-0001-plr.pdf

Original ruling text

ST 16-0001-PLR 01/13/2016 HOTEL OPERATORS’ TAX
This letter discusses the Hotel Operators’ Tax Act. See 86 Ill. Adm. Code 480.101(b)(3). (This
is a PLR.)
January 13, 2016

Dear Xxxxx:
This letter is in response to your letter dated December 28, 2012, in which you request
information. The Department issues two types of letter rulings. Private Letter Rulings (“PLRs”) are
issued by the Department in response to specific taxpayer inquiries concerning the application of a tax
statute or rule to a particular fact situation. A PLR is binding on the Department, but only as to the
taxpayer who is the subject of the request for ruling and only to the extent the facts recited in the PLR
are correct and complete. Persons seeking PLRs must comply with the procedures for PLRs found in
the Department’s regulations at 2 Ill. Adm. Code 1200.110. The purpose of a General Information
Letter (“GIL”) is to direct taxpayers to Department regulations or other sources of information regarding
the topic about which they have inquired. A GIL is not a statement of Department policy and is not
binding on the Department. See 2 Ill. Adm. Code 1200.120. You may access our website at
www.tax.illinois.gov to review regulations, letter rulings and other types of information relevant to your
inquiry.
Review of your request disclosed that all the information described in paragraphs 1 through 8 of
Section 1200.110 appears to be contained in your request. This Private Letter Ruling will bind the
Department only with respect to ABC for the issue or issues presented in this ruling, and is subject to
the provisions of subsection (e) of Section 1200.110 governing expiration of Private Letter Rulings.
Issuance of this ruling is conditioned upon the understanding that neither ABC nor a related taxpayer
is currently under audit or involved in litigation concerning the issues that are the subject of this ruling
request. In your letter you have stated and made inquiry as follows:
Please accept this letter as a request for a Private Letter Ruling pursuant to Illinois
Administrative Code § 1200.110. The undersigned person (the “Taxpayer”) requests the
ruling to determine his tax liabilities under the Illinois Hotel Operator’s Occupation Tax,
35 ILCS 145/1 et seq. (the “HOOT”). On Month 21, 20XX, Taxpayer made a payment –
under protest – of $$$ in taxes to the Illinois Department of Revenue. Taxpayer believes
that, pursuant to 86 Ill. Adm. Code 480.101(b)(2), he should not have been required to
pay any HOOT on any income he received while renting out accommodations through a
private club.
In the alternative, Taxpayer submits that even if the IDOR determines that he is liable for
HOOT, that pursuant to Section 2 of Article IX of the 1970 Illinois Constitution, the IDOR
should abstain from enforcing or seeking to collect the HOOT fro [sic] Taxpayer, unless
and until the IDOR can determine a reasonable and uniform method of assessing and
collecting said HOOT from all members of the class of people similarly situated to
Taxpayer. Accordingly, Taxpayer requests a Private Letter Ruling in his favor, as well as
a refund of taxes paid.

The following paragraphs and attachments provide a complete statement of the facts and
other information necessary to process Taxpayer’s request:
COMPLETE STATEMENT OF FACTS
1.

The interested party is the undersigned Taxpayer.

2.

Taxpayer resides in a two-bedroom, two bathroom apartment in CITY 1, Illinois,
located at ADDRESS, CITY 1, Illinois, Unit (the “Apartment”). The basic floorplan
[sic] of the Apartment is attached hereto as Exhibit 1.

3.

The Apartment is located in a 20-story condominium building that contains over
100 separate units.

4.

Taxpayer is the sole resident in the Apartment. The second “guest” bedroom is
furnished with a cloth sofa, a television, and a coffee table. There is no bed in the
second “guest” bedroom. Taxpayer sleeps in the first “master” bedroom, which is
furnished with a queen sized bed, dresser and end tables. There is a common
living room between the two bedrooms that contains a cloth sofa and a leather
sofa, a dining table, a television, and other assorted furniture. There is also a
common kitchen between the two bedrooms.

5.

In July 2012, Taxpayer learned of a website, COMPANY.com. COMPANY
describes itself as a “trusted community marketplace for people to list, discover,
and book unique accommodations around the world – online or from a mobile
phone.” On its website the COMPANY states that it operates in “more than 33,000
cities and 192 countries” and that, through its website, it has arrange [sic] for “over
10 million nights booked” and has facilitated “over 600 million Social Connections.”

6.

COMPANY operates solely on the internet, and holds itself out as nothing more
than an “online platform that connects hosts who have accommodations to rent
with guests seeking to rent such accommodations.” The COMPANY.com Terms
of Service (last updated MONTH 22, 20XX) are attached hereto as Exhibit 2, and
incorporated herein by reference (all of COMPANY’s terms, including its Privacy
Policy, Host Guarantee Terms, and the Guest Refund Policy, can be found on
COMPANY’S website.

7.

Particularly, in its Terms of Service, COMPANY defines “Host” as “a Member who
creates a Listing via the Site, Application and Services.” A “Guest” is defined as
“a Member who requests a booking of an Accomodations [sic] via the Site,
Application or Services, or a Member who stays at an Accomodation [sic] and is
not the Host for such Accomodation.” [sic]

8.

In its Terms of Service, COMPANY defines a “Member” as “a person who
completes COMPANY’s account registration process, including, but not limited to,
Hosts and guests, as described under “Account Registration” below.”

9.

In July 20XX, Taxpayer became a “member” of COMPANY, by completing the
Account Registration process, which included filling out personal information and
providing credit card information.

10.

Taxpayer also created a “listing” for this second bedroom.

11.

COMPANY goes to great lengths to protect its Members. The personal information
gathered (including the credit card information) allows for COMPANY to positively
identify either “hosts” or “guests” that misbehave or cause injury or damage. All
members are allowed to post reviews – both positive and negative – of other
members with whom they have interacted, on the COMPANY website, and
members may review these comments before booking or accepting a request to
book an accommodation. [sic] If a “guest” experiences a travel issue, including,
for instance, a last-minute cancellation by the host, or an accommodation that
does not match the listing description or pictures, COMPANY offers such a guest
a full refund, and may even find the guest alternative accommodations. In turn,
“hosts” are provided an insurance policy of up to $1 million as well as access to a
security deposit that is automatically charged against the guest’s credit card upon
booking. These security assurances are only provided to COMPANY members.

12.

Further, COMPANY allows for anonymity from the general public. A person would
have no way of knowing that Taxpayer is a member of COMPANY, or that he has
a listing available on the website, unless that person becomes a registered
COMPANY Member. COMPANY’s Terms of Service state: “In order to access
certain features of the Site and Application, and to book an Accommodation or
create a Listing, you must register to create an account ... and become a Member.”
Thus, Taxpayer’s listing is only viewable to COMPANY members, and only
COMPANY members who have contacted Taxpayer through the website, and that
Taxpayer has accepted, can learn Taxpayer’s exact address or discover any other
personal identifying information about Taxpayer.

13.

Since MONTH 20XX, Taxpayer has hosted several COMPANY guests, and has
received approximately $$$ as compensation from MONTH 1, 20XX to MONTH
31, 20XX. Each guest contacted Taxpayer through the COMPANY website, and
booked accommodations through the website. All of the guests that have booked
with Taxpayer have stayed for less than 30 days, although each has the option to
stay indefinitely, and some guests have stated their intent to return for longer stays.

14.

Even though he has received compensation, however,Taxpayer is not ‘in the
business” of renting out his second bedroom. Taxpayer has a full-time job in CITY
1 as PROFESSION, and like anyone else, Taxpayer enjoys his privacy. Taxpayer
lists his $$ rate for rental of the second bedroom not for business reasons, but
more as a way for Taxpayer to avoid having a full-time flatmate every day of the
month, and to “weed out” potentially undesirable “guests” who are unable to afford
even $$.

15.

Taxpayer participates in COMPANY because there is a social benefit to being an
active member of a network. Taxpayer also enjoys the social connections made
through COMPANY, and has actually made friends through the website. Taxpayer
also enjoys travelling himself, and would like to someday use COMPANY to book
accommodations with other members in other cities. Taxpayer has been reviewed
positively by several of his guest, and Taxpayer himself has posted favorable
reviews of guests that he has hosted.

16.

In MONTH 20XX, Taxpayer realized that the compensation he was receiving might
be subject to a HOOT. Taxpayer was unsure and contacted COMPANY for
guidance. Per their Terms of Service, COMPANY declined to provide specific tax
advice. See Exh. 1 (“COMPANY cannot and does not offer Tax-related advice to
any Members of the Site...”).

17.

Taxpayer then contacted the IDOR. The IDOR stated that they did not know the
answer of whether Taxpayer owed a HOOT but advised that Taxpayer register as
a hotel operator business and that Taxpayer pay the tax regardless, and seek a
refund later.

18.

Following this conversation, Taxpayer registered with the IDOR as a “hotel
operator.” A true and correct copy of the Illinois Business Authorization Certificate
of Registration is attached hereto as Exhibit 3.

19.

On MONTH 11, 20XX, Taxpayer wrote a letter to the IDOR seeking guidance or a
private letter ruling. A true and correct copy of this letter is attached hereto as
Exhibit 4.

20.

On MONTH 11, 20XX, Taxpayer received a “Notice Before Collection Action” from
the IDOR. A true and correct copy of this Notice is attached hereto as Exhibit 5.

21.

On MONTH 30, 20XX, the IDOR sent Taxpayer a General Information Letter in
response. [sic] A true and correct copy of the IDOR GIL response is attached
hereto as Exhibit 6.

22.

In its GIL, the IDOR stated, in pertinent part:
If a person engaged in the business of renting, leasing or letting rooms does
not intend for its rooms to be “exclusive” (like a school, hospital or private
club) but, rather, welcomes and encourages “other individuals and
organizations” to use its facilities (e.g., rooms), even though those
individuals or organizations may be screened, the Department would
generally consider the facilities open to the public. In contrast, if a person
engaged in the business of renting leasing or letting rooms intends for its
rooms to be “exclusive” (e.g., rented only to members of a private club and
not to the general public), the Department would not consider the facilities
open to the public and, thus, not subject to HOOT.
We are unable to give you the specific guidance you requested because the
taxability or nontaxability of the transactions outlined in your letter is
dependent upon the specific facts surrounding those transactions

23.

On MONTH 21, 20XX, Taxpayer dutifully completed the RHM-1 HOOT Returns
from MONTH 2012 through MONTH 2012, and paid $$$ in Hotel Tax under
protest. True and correct copies of Taxpayer’s RHM-1 Forms, a copy of the check
representing payment, and a copy of Taxpayer’s Notice of Payment Under Protest
form, are attached hereto as Exhibit 7.

CONTRACTS, LICENSES, AGREEMENTS
24.

Taxpayer is a member of and host with the COMPANY website pursuant to the
Terms of Service attached hereto as Exhibit 2. Other policies and terms are
available on the COMPANY website.

25.

Taxpayer is authorized to do business as a “hotel operator” with the State of Illinois
(even though Taxpayer objects that he should not be considered a “hotel operator”
notwithstanding his authorization to do business as such).

TAX PERIOD AT ISSUE / NO PENDING AND PRIOR RULINGS
26.

The tax period at issue is MONTH 1, 20XX through MONTH 31, 20XX.

27.

There is no pending audit or litigation with the IDOR, to the best of Taxpayer’s
knowledge.

28.

To the best of Taxpayer’s knowledge, the IDOR has not previously ruled on the
same or a similar issue for the Taxpayer or a predecessor.

AUTHORITIES AND ARGUMENT IN SUPPORT OF TAXPAYER’S CONCLUSION
I.

The HOOT Does Not Apply To Taxpayer.

There are three (3) reasons why the HOOT Act does not and should not apply to
Taxpayer.
First, Taxpayer is not ‘in the business’ of renting out his second bedroom.
Second, Taxpayer’s second bedroom does not meet the definition of a “hotel.”
Third, Taxpayer does not rent his second bedroom to the general public, but only within
and exclusively to members of a private club – COMPANY.
“Taxing laws are to be strictly construed and they are not to be extended beyond the clear
import of the language used. If there is any doubt in their application they will be
construed most strongly against the government and in favor of the taxpayer.” Oscar L.
Paris Co. v. Lyonsi, 8 Ill. 2d 590, 598 (1956). Under the HOOT Act, the IDOR is authorized
to impose a tax “upon persons engaged in the business of renting, leasing or letting rooms
in a hotel...” 35 ILCS 145/3(a). The HOOT Act defines a “hotel” as “any building or
buildings in which the public may, for a consideration, obtain living quarters, sleeping or
housekeeping accommodations.” 35 ILCS 145/2(1).
The first reason why the HOOT does not apply to Taxpayer is that Taxpayer is not “in the
business” of renting out rooms in a hotel. There is no Illinois authority directly on point
about what it means for a person to be engaged “in the business” of anything, let alone
running a hotel. However, the facts do not support the conclusion that Taxpayer
participates in COMPANY for business reasons, as opposed to social reasons.
COMPANY itself boasts about its 600 million social connections that it fosters, and

Taxpayer submits that he is selective in terms of guests, that he has fostered ongoing
friendships with guests, and that he hopes to “return the favor” and stay with one of his
former guests someday. There are, at worst, mixed motivations behind Taxpayer’s
activity.
The objective facts also do not support a finding that Taxpayer is engaged “in the
business” of running a hotel. The compensation received by Taxpayer can only be
described as incidental to his overall net income. Taxpayer has made no substantial
investment of his own capital into renting out his second bedroom – he has not even
bought a proper bed for his guests, who “crash” on his sofa – and he created his listing
for free on the internet.
Can it be sufficient that, regardless of his motivations or the amount of compensation
received, the mere fact that Taxpayer receives compensation from his guests in exchange
for lodging means that he is liable for HOOT?
Taxpayer submits that this loose interpretation of the HOOT Act would be unconscionably
broad, as it would mean that every time Taxpayer’s own mother stays with Taxpayer in
that same second bedroom, and every time Taxpayer’s mother insists on paying for
dinner or paying for groceries or household supplies herself, that such “compensation” is
potentially taxable under the HOOT Act. The applicability of the HOOT Act cannot be
reduced to the singular criteria of whether compensation is paid over in exchange for
lodging.
The second reason why the HOOT does not apply to Taxpayer is that Taxpayer’s second
bedroom is not a “hotel” because it is not a building. The definition of “hotel” under the
HOOT Act is clear: the HOOT only applies to “hotels” which are defined only as “any
building or buildings in which the public may, for a consideration, obtain living quarters,
sleeping or housekeeping accommodations.” 35 ILCS 145/2(1).
Here, the building is located at ADDRESS. It has 20 floors, over 100 units and common
areas. Taxpayer does not and could not hold out the entire building for rent to any of his
guests. In fact, Taxpayer does not even hold out his entire Apartment for rent to any of
his guests. His guests are not authorized to enter into Taxpayer’s master bedroom, for
instance, without his permission.
The definition of a “hotel” under the HOOT Act includes “inns, motels, tourist homes or
courts, lodging houses, rooming houses and apartment houses.” 35 ILCS 145/2(1). Each
of those enumerated examples, however, is a free-standing building. The Illinois
General Assembly could have, but did not, categorize the renting out (or even subletting)
a single room inside a single apartment unit as part of the definition of a “hotel.”
Construing the term “hotel” narrowly makes sense, because the very definition of a “hotel”
is a building containing accommodations that is open to the public. When one thinks of
a hotel, one thinks of (at a minimum) a front desk and common amenities. Here, there is
no such “front desk” and there are no “common amenities” that are open to Taxpayer’s
guests. The guest has access to the second bedroom and the sofa therein. Taxpayer is
not renting out a “building” and thus, cannot be considered a “hotel” operator.

Third, the HOOT should not apply to Taxpayer because the definition of a “hotel” is an
accommodation that is made available to “the public.” Under the IDOR’s own regulations
implementing the HOOT Act, 86 Ill. Adm. Code 480.101(b)(2), the HOOT does not apply
to private clubs that are not open to the public:
Since the [HOOT] is limited to the renting of rooms to the “public,” a
private club which restricts its renting of rooms to its members and
their guests would not be liable for the tax on its rental receipts from
such rooms.
There is no direct authority in Illinois interpreting the HOOT Act and whether or when it
applies to “private clubs.” However, there is persuasive authority from outside of the State
of Illinois. In Ambassador Athletic Club v. Utah State Tax Commission, 27 Utah 2d 377,
496 P.2d 883 (Utah 1972), the Utah Supreme Court considered whether an athletic club
had to pay a similar Utah hotel operators’ tax on the renting of rooms to its members, their
guests, and the members of clubs in other cities where the club had a reciprocal
agreement. The court noted a Kentucky court’s definition of a hotel as “established and
maintained for the purpose of serving the public” and as “an invitation to the public to
become its guests,” and held that “since [the club] does not hold itself out as providing
services to the public as a whole, it does not perform the function of a hotel.” Ambassador
Athletic Club, 27 Utah 2d at 379 (quoting Clemons v. Meadows, 123 Ky. 178, 94 S.W. 13
(Ky. 1906)). A similar outcome was found by the Kansas Supreme Court in City of
Independence v. Richardson, 117 Kan. 656, 232 P. 1044 (Kan. 1925), where the Kansas
Supreme Court held that a hotel license tax could not be applied to the owner of a private
rooming house because the rooms were not available or open to the general public
indiscriminately.
Here, Taxpayer does not rent out his second bedroom to the general public. Only
COMPANY members can view his listing and book an accommodation. There are
security and anonymity barriers that prohibit the “general public” from viewing his listing
or booking an accommodation with Taxpayer, unless and until they complete the
registration process and become Members. Like the Utah athletic club, COMPANY is
nothing more than a private club and accordingly, pursuant to 86 Ill. Adm. Code
480101(b)(2) [sic], the HOOT should not apply to Taxpayer’s renting out his second
bedroom through COMPANY exclusively to his fellow COMPANY members.
II.

Even If The IDOR Concludes That The HOOT Applies To Taxpayer, The IDOR
Should Abstain From Enforcing Or Collecting The HOOT From Taxpayer
Because It Would Be Unfair to Do So.

Article IX, Section 2, 1970 Illinois Constitution:
Section 2.
Non-Property Taxes--Classification, Exemption,
Deductions, Allowances and Credits. In any law classifying the
subjects or objects of non-property taxes or fees, the classes shall be
reasonable and the subjects and objects within each class shall be
taxed uniformly. Exemptions, deductions, credits, refunds, and other
allowances shall be reasonable.

As further authority in support, Taxpayer refers the IDOR to Northwestern University v.
City of Evanston, 221 Ill. App. 3d 893 (1st Dist. 1991), where the Illinois Appellate Court
stated that “the test for determining whether a tax classification meets the requirements
of uniformity is twofold: (1) whether any real and substantial differences exist between
those who are taxed and those who are not, and (2) whether the classification is
reasonably related to a legislative purpose.” Id. at 896.
The problem with attempting to enforce or collect the HOOT against Taxpayer is that,
even if it could technically be read to apply, it could never be enforced uniformly against
all other members of the COMPANY host “class.” The reason is simple: unless an
COMPANY member voluntarily registers as a “hotel operator” with the IDOR and
voluntarily discloses his COMPANY income on his RHM-1 monthly HOOT forms, there is
no reasonable ways [sic] that the IDOR would ever know if a person owes HOOT. This
is because there are privacy walls. First, there is an intrinsic privacy wall created by the
nature of the internet itself. Unlike a “brick-and-mortar” hotel or motel, an “online” hotel
operator does not have to hang out a shingle, put up a sign, or otherwise publicly declare
that he or she has accommodations for rent. Second, within COMPANY, there is a
separate “privacy wall” – only members can view listings, and even then, the “host” can
control which member-guests can view the host’s personal identifying information. Only
a successfully consummated booking results in the “reveal” of the host’s name, phone
number and address.
Thus, applying the HOOT to Taxpayer (and other COMPANY members) would simply
create a society of scofflaws. If only “do-gooders” who (1) voluntarily registered with the
IDOR and (2) honestly filled out the RHM-1 forms were liable for paying the tax, then
there would never be any future “do-gooders” because “scofflaws” would never be
discovered (because of the aforementioned “privacy walls”). Because there is no
possibility of uniformly enforcing the HOOT against COMPANY hosts, it would be
unconstitutional to apply the HOOT solely against those that voluntarily register with the
IDOR and honestly fill out RHM-1 HOOT forms.
AUTHORITIES CONTRARY TO TAXPAYER’S PETITION
29.

Taxpayer is unable to locate any authorities contrary to his views.

DEPARTMENT’S RESPONSE:
The Hotel Operators' Occupation Tax Act (“HOOT”) imposes a tax upon persons engaged in the
business of renting, leasing or letting rooms in a hotel, as defined in the Act. HOOT defines “hotel” to
include any building or buildings in which the public may, for consideration, obtain living quarters,
sleeping or housekeeping accommodations. See 35 ILCS 145/2(1). HOOT defines “rent” as “the
consideration received for occupancy, valued in money, whether received in money or otherwise,
including all receipts, cash, credits and property or services of any kind or nature.” See 35 ILCS
145/2(6). The definition of “rent” must be read in conjunction with the term “occupancy.” HOOT defines
“occupancy” as “the use or possession, or the right to the use or possession, of any room or rooms in
a hotel for any purpose, or the right to the use or possession of the furnishings or to the services and
accommodations accompanying the use and possession of the room or rooms.” See 35 ILCS 145/2(3).

The consideration you receive for occupancy of the room meets the definition of “rent” contained
in HOOT. You rent the room to provide living quarters. The lack of a bed in the room is not important.
In a recent General Information letter, the Department reviewed facts similar to the ones provided in
your letter. In that letter, the Department stated:
“If a person engaged in the business of renting, leasing or letting rooms
does not intend for its rooms to be “exclusive” (like a school, hospital or
private club) but, rather, welcomes and encourages “other individuals and
organizations” to use its facilities (e.g. rooms), even though those
individuals or organizations may be screened, the Department would
generally consider the facilities open to the public. In contrast, if a person
engaged in the business of renting, leasing or letting rooms intends for its
rooms to be “exclusive” (e.g., rented only to members of a private club and
not to the general public), the Department would not consider the facilities
open to the public and, thus, not be subject to HOOT.”
In your letter you state that “COMPANY operates solely on the internet, and holds itself out as
nothing more than an online platform that connects hosts who have accommodations to rent with
guests seeking to rent such accommodations.”
We liken the arrangement you described you have with COMPANY to be one where COMPANY
“facilitates” the rental of your second bedroom. COMPANY facilitates the rental between you, as “Host”,
and the person who wishes to rent your room, the “rentee”. COMPANY does not make the decision to
rent your room; you make the decision and are paid by the rentee to permit the rentee to rent your
room. You also state in your letter that “guests” stay for less than 30 days. Based upon the information
you provided, it is the Department’s position that the consideration you receive from the rental of the
room in your condominium is subject to HOOT.
The factual representations upon which this ruling is based are subject to review by the
Department during the course of any audit, investigation, or hearing and this ruling shall bind the
Department only if the factual representations recited in this ruling are correct and complete. This
Private Letter Ruling is revoked and will cease to bind the Department 10 years after the date of this
letter under the provisions of 2 Ill. Adm. Code 1200.110(e) or earlier if there is a pertinent change in
statutory law, case law, rules or in the factual representations recited in this ruling.
I hope this information is helpful. If you have further questions concerning this Private Letter
Ruling, you may contact me at 782-2844. If you have further questions related to the Illinois sales tax
laws, please visit our website at www.tax.illinois.gov or contact the Department’s Taxpayer Information
Division at (217) 782-3336.
Very truly yours,

Richard S. Wolters
Chairman, Private Letter Ruling Committee
RSW:DMB: