When does an out-of-state seller have enough connection ('nexus') with Illinois to owe Retailers' Occupation Tax or to have to collect Use Tax from Illinois customers, and how does Illinois treat related issues like software, cloud computing, drop shipments, and short-term rental platforms?

Plain-English summary

An organization compiling a multistate survey of state tax departments asked Illinois to fill out a detailed questionnaire on sales tax nexus policies, covering topics like nexus-creating activities, sourcing, the sharing economy, cloud computing, and refund claims. The Illinois Department of Revenue explained that it could not answer the survey in the yes/no format requested because nexus determinations are "very fact specific" and cannot be addressed in a General Information Letter. Instead, the Department gave a general overview of its nexus framework and touched on several related sales-tax topics raised in the questionnaire.

On nexus itself, the letter explains that an "Illinois Retailer" is a seller who makes sales of tangible personal property in Illinois and is therefore liable for Retailers' Occupation Tax, while a "retailer maintaining a place of business in Illinois" (defined at 86 Ill. Adm. Code 150.201(i)) must register and collect Use Tax on behalf of its Illinois customers even without incurring Retailers' Occupation Tax liability itself. The Department pointed to Quill Corp. v. North Dakota for the constitutional two-prong nexus test: due process is satisfied when a seller purposely avails itself of an Illinois market, and the Commerce Clause additionally requires physical presence, which under Illinois case law (Brown's Furniture, Inc. v. Zehnder) can include any agent or representative present in the state, not just an office. The letter also describes Illinois' "click-through nexus" provisions: a retailer with an Illinois-based referral contract that produces more than $10,000 in referred sales over four quarters is presumed to be "maintaining a place of business" here, subject to rebuttal, following the 2015 fix to the provision the Illinois Supreme Court struck down in Performance Mktg. Ass'n, Inc. v. Hamer.

Beyond core nexus, the Department briefly addressed several adjacent issues raised in the survey. For the sharing economy, it noted that Illinois' Hotel Operators' Occupation Tax (HOOT) taxes the host/owner who rents out accommodations, not a third-party booking platform like Airbnb. On computer software, canned (pre-written) software is taxable regardless of delivery method, including electronic downloads, while custom software prepared to a customer's special order is generally not; software licenses can also escape tax if they meet the specific written-agreement criteria in 86 Ill. Adm. Code 130.1935(a)(1). Cloud-based/SaaS arrangements where software is never downloaded are currently not taxed, though the Department said it continues to review this area and would apply any future change only prospectively.

Finally, the letter covers drop shipments (an out-of-state purchaser buying for resale and having the seller ship directly to the purchaser's Illinois customer, which requires a Certificate of Resale under 86 Ill. Adm. Code 130.1405), refund claims (available only to the party that actually remitted the erroneously paid tax), and the availability of qui tam and class-action lawsuits under the Illinois False Claims Act for underpaid sales tax.

What this means for you

If you are an out-of-state seller shipping into Illinois

You may owe Illinois Retailers' Occupation Tax or have Use Tax collection duties if you have physical presence in Illinois — which can be as limited as an agent, installer, or a referral/affiliate contract generating over $10,000 in Illinois-sourced sales in a rolling four-quarter period. If you have no such presence, you are not required to collect tax, but your Illinois customers still owe self-assessed Use Tax on their purchases.

If you sell software, SaaS, or digital goods into Illinois

Canned software is taxable however it's delivered, including downloads, unless it qualifies as an exempt written license meeting all the criteria in 86 Ill. Adm. Code 130.1935(a)(1) (signed agreement, use/duplication restrictions, no unauthorized sublicensing, replacement-copy policy, and return/destruction at license end). Custom-built software and pure cloud-based/SaaS access (no software transferred to the customer's device) are generally not currently taxed, but the Department has flagged that its cloud-computing position is under ongoing review.

If you operate a short-term rental platform or drop-ship goods into Illinois

Platforms like Airbnb are not themselves liable for Hotel Operators' Occupation Tax — that liability falls on the property owner/host. If you drop-ship into Illinois as a registered seller, you need a valid Certificate of Resale from your out-of-state purchaser to avoid having to charge and collect Illinois tax on that sale yourself.

Common questions

Q: Does this letter give a definitive nexus answer for my specific business?
A: No. The Department expressly declined to answer the survey's yes/no nexus questions because nexus is fact-specific, and this is only a non-binding General Information Letter, not a ruling on particular facts.

Q: What two things does Illinois look at to decide if a remote seller has nexus?
A: Following Quill Corp. v. North Dakota, Illinois applies a due-process test (purposeful availment of the Illinois market) and a Commerce Clause test (physical presence in Illinois, which can include agents or representatives, not just offices).

Q: Does a referral/affiliate website link automatically create Illinois nexus?
A: It can. Since January 1, 2015, a contract where an Illinois-based person refers customers using a tracked promotional code or link, generating more than $10,000 in referred sales over the preceding four quarters, creates a rebuttable presumption of nexus under 35 ILCS 105/2(1.1).

Q: Is cloud-based software (SaaS) taxable in Illinois?
A: Not currently, according to this letter — cloud-based delivery where software is never downloaded to the customer's device is not subject to tax, though the Department says it continues to review this position and would apply any change only going forward.

Citations and references

• Quill Corp. v. North Dakota, 112 S. Ct. 1904 (1992) — constitutional nexus test (due process + physical presence)
• 2 Ill. Adm. Code 1200.110 — Private Letter Ruling procedures
• 2 Ill. Adm. Code 1200.120 — General Information Letter procedures (basis for this letter)
• Hartney Fuel Oil Co. v. Hamer, 2013 IL 115130 — basis for amended Illinois retailer sourcing regulations
• 86 Ill. Adm. Code 150.201(i) — definition of "retailer maintaining a place of business in Illinois"
• 86 Ill. Adm. Code 150.801 — Use Tax collector registration requirement
• Brown's Furniture, Inc. v. Zehnder, 171 Ill.2d 410 (1996) — physical presence includes agents/representatives
• 35 ILCS 105/2(1.2) — affiliate nexus (shared name/trademark plus commission)
• Performance Mktg. Ass'n, Inc. v. Hamer, 998 N.E.2d 54 (2013) — struck down 2011 click-through nexus provision
• 35 ILCS 105/2(1.1) — click-through/referral nexus (Use Tax Act, effective 2015)
• 35 ILCS 110/2(1.1) — click-through/referral nexus (Retailers' Occupation Tax Act)
• 35 ILCS 145/2(1), (3), (6) — Hotel Operators' Occupation Tax Act definitions of "hotel," "occupancy," and "rent"
• 86 Ill. Adm. Code 130.1935 — taxability of canned vs. custom computer software and license exemption criteria
• 86 Ill. Adm. Code 130.101 — Retailers' Occupation Tax Act general imposition
• 86 Ill. Adm. Code 150.101 — Use Tax Act general imposition
• 86 Ill. Adm. Code 140.101 through 140.109 — Service Occupation Tax rules
• 86 Ill. Adm. Code 130.225 — drop shipment regulations
• 86 Ill. Adm. Code 130.1405 — Certificate of Resale requirements
• 86 Ill. Adm. Code 130.1501(b) — refund/credit claim requirements
• 740 ILCS 175 — Illinois False Claims Act (qui tam suits)
• Geary v. Dominick's Finer Foods, Inc., 129 Ill. 2d 389 (1989) — class actions for wrongly paid taxes
• Harrison Sheet Steel Co. v. Lyons, 15 Ill. 2d 539 (1959) — class actions for wrongly paid taxes

Source

• Landing page: https://taxarchive.illinois.gov/research/legal/letter-rulings/sales-tax/2017.html
• Original PDF: https://tax.illinois.gov/content/dam/soi/en/web/taxarchive/research/legal/letter-rulings/sales-tax/2017/st-17-0007-gil.pdf

Original ruling text

ST 17-0007-GIL 03/02/2017 NEXUS
This letter responds to a questionnaire regarding nexus. See Quill Corp. v. North Dakota, 112
S. Ct. 1904 (1992). (This is a GIL.)

March 2, 2017

Dear Xxxxx:
This letter is in response to your letter dated November 10, 2016, in which you requested
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.
The nature of your inquiry and the information you have provided require that we respond with
a GIL. In your letter you have stated and made inquiry as follows:
We are writing to ask you to complete the questionnaires for the 2017 ABC Survey of
State Tax Departments on behalf of your state. Attached is an Excel spreadsheet
containing the questions for 2017. One column of the spreadsheet has all of your state’s
responses for 2016. An adjacent column is there for you to record your responses for
2017. To avoid any errors, please fill out the 2017 column even if the answer has not
changed from 2016.
Additionally, we ask that you note where you have intentionally left questions blank. We
are required to follow-up regarding any unanswered question; and making note of
intentionally unanswered questions allows us to process and analyze the data faster.
This can be accomplished by typing “blank” or “no response” in the answer column or
simply noting in your e-mail that questions were left blank intentionally.
The survey covers many of the gray areas of state tax law. Your responses will provide
useful guidance for taxpayers in complying with your state’s laws.
The questionnaires should be completed based on state law as of January 1,
2017. If you would like to add or change information you have previously recorded in
the comments section, please make those modifications in red font.
Some new questions have been added to this year’s questionnaires.
questions and subsections are denoted in blue font.

The new

ST 17-0007-GIL
Page 2
Please return your questionnaires to us by January 31, 2017.
Excel spreadsheets should be e-mailed to me.

Your completed

Your responses, along with the responses we receive from other states, will be
published by ABC, a leading publisher of international, federal, and state tax analysis.
More information about ABC can be found at www.XXXXX.com.
If you have any questions about this or if there is any way I can help you to complete
this year’s questionnaires, please contact me.
I look forward to working with you.
………..
In your questionnaire, you have stated, in part, as follows:
XIII.
A.

Sales Tax Nexus Policies

B.
C.
D.

Please identify any statute, regulation, or administrative pronouncement
that sets forth your state’s sales tax nexus policy.
Nexus Enforcement Policies
Sourcing and Method of Delivery
Sharing Economy (New for 2017)

XIV.

Sales Tax Nexus Creating Activities

Please indicate “Yes” or “No” to show whether each of the following activities or
relationships performed by an out-of-state corporation would, by itself, create
substantial nexus with your state for purposes of triggering the imposition of sales tax
collection requirements on the out-of-state corporation. When determining whether the
listed activity/relationship would create substantial nexus, assume that each item is the
only activity/relationship the out-of-state corporation has in your state. Also assume that
the out-of-state corporation has no property or employees located in your state.
A “Yes” response means that an out-of-state corporation's performance of the listed
activity/relationship would, by itself, create substantial nexus and trigger the imposition
of sales tax collection requirements on the out-of-state corporation. A “No” response
means that an out-of-state corporation's performance of the listed activity/relationship
would not, by itself, trigger nexus for purposes of your state's sales tax.
For the questions that you believe require more than a “Yes” or “No” answer, please set
forth in the comments section the factors that your state would consider in making a
nexus determination.
A.
B.
C.
D.
E.

General Activities
Remote Sales
Temporary or Sporadic Presence
Activities of Unrelated Parties
Financial Activities

ST 17-0007-GIL
Page 3
F.
G.
H.
I.
J.
K.
L.
M.
N.
O.

Activities with Affiliates
Internet Activities
Activities Related to Digital Property
Distribution and Delivery
Third-Party Solicitation Activities and Attributional Nexus
Transactions Involving Franchise Agreements
Service Providers
Cloud Computing
Registration with State Agencies/Departments
Drop Shipment Transactions

XV. Refund Claims, Qui Tam and Class Action Lawsuits
A. Refund Claims (New for 2016)
B. Qui Tam and Class Action Lawsuits
DEPARTMENT’S RESPONSE:
We are unable to respond to your nexus survey in the format provided. Determinations
regarding nexus are very fact specific and cannot be addressed in the context of a General
Information Letter. However, we can provide you with basic guidelines that may be used to determine
whether a seller would be considered “an Illinois retailer” subject to Retailers’ Occupation Tax liability
or “a retailer maintaining a place of business in Illinois” subject to Use Tax collection duties from their
Illinois customers.
NEXUS
An “Illinois Retailer” is one who makes sales of tangible personal property in Illinois. The Illinois
Retailer is then liable for Retailers' Occupation Tax on gross receipts from sales and must collect the
corresponding Use Tax incurred by the purchasers. Our regulations were amended in response to the
Illinois Supreme Court’s decision in Hartney Fuel Oil Co. v. Hamer, 2013 IL 115130. The regulations
specify the selling activities that trigger Retailers’ Occupation Tax liability in Illinois.
Another type of retailer is the retailer maintaining a place of business in Illinois. The definition
of a “retailer maintaining a place of business in Illinois” is described in 86 Ill. Adm. Code 150.201(i).
This type of retailer is required to register with the State as an Illinois Use Tax collector. See 86 Ill.
Adm. Code 150.801. The retailer must collect and remit Use Tax to the State on behalf of the
retailer’s Illinois customers even though the retailer does not incur any Retailers' Occupation Tax
liability.
The United States Supreme Court in Quill Corp. v. North Dakota, 112 S.Ct. 1904 (1992), set
forth the current guidelines for determining what nexus requirements must be met before a person is
properly subject to a state's tax laws. The Supreme Court has set out a 2-prong test for nexus. The
first prong is whether the Due Process Clause is satisfied. Due process will be satisfied if the person
or entity purposely avails itself or himself of the benefits of an economic market in a forum state. Quill
at 1910. The second prong of the Supreme Court's nexus test requires that, if due process
requirements have been satisfied, the person or entity must have physical presence in the forum
state to satisfy the Commerce Clause. A physical presence is not limited to an office or other physical

ST 17-0007-GIL
Page 4
building. Under Illinois law, it also includes the presence of any agent or representative of the seller.
The representative need not be a sales representative. Any type of physical presence in the State of
Illinois, including the vendor’s delivery and installation of his product on a repetitive basis, will trigger
Use Tax collection responsibilities. Please refer to Brown’s Furniture, Inc. v. Zehnder, 171 Ill.2d 410
(1996).
The final type of retailer is the out-of-State retailer that does not have sufficient nexus with
Illinois to be required to submit to Illinois tax laws. A retailer in this situation does not incur Retailers’
Occupation Tax on sales into Illinois and is not required to collect Use Tax on behalf of its Illinois
customers. However, the retailer’s Illinois customers will still incur Use Tax liability on the purchase of
the goods and have a duty to self-assess and remit their Use Tax liability directly to the State.
Beginning July 1, 2011, the definition of a “retailer maintaining a place of business” was
amended to include additional types of retailers. A retailer maintaining a place of business also
includes a retailer having a contract with a person located in this State under which:
A. The retailer sells the same or substantially similar line of products as the person located in
this State and does so using an identical or substantially similar name, trade name, or trademark as
the person located in this State; and
B. The retailer provides a commission or other consideration to the person located in this State
based upon the sale of tangible personal property by the retailer. See 35 ILCS 105/2(1.2).
These provisions only apply if the cumulative gross receipts from sales of tangible personal
property by the retailer to customers in this State under all such contracts exceed $10,000 during the
preceding 4 quarterly periods. Please note that in Performance Mktg. Ass'n, Inc. v. Hamer, 998
N.E.2d 54 (2013) the Illinois Supreme Court struck down 35 ILCS 105/2(1.1) and 35 ILCS 110/2(1.1),
a “click-thru nexus provision” enacted in 2011. However, new provisions became effective January 1,
2015. The following provisions address the court’s concerns in Performance Mktg. Ass'n, Inc. v.
Hamer, 998 N.E. 2d 54 (2013).
Beginning January 1, 2015, a retailer maintaining a place of business also includes a retailer
having a contract with a person located in this State under which the person, for a commission or
other consideration based upon the sale of tangible personal property by the retailer, directly or
indirectly refers potential customers to the retailer by providing to the potential customers a
promotional code or other mechanism that allows the retailer to track purchases referred by such
persons.
Examples of mechanisms that allow the retailer to track purchases referred by such persons
include but are not limited to the use of a link on the person's Internet website, promotional codes
distributed through the person's hand-delivered or mailed material, and promotional codes distributed
by the person through radio or other broadcast media. These provisions apply only if the cumulative
gross receipts from sales of tangible personal property by the retailer to customers who are referred
to the retailer by all persons in Illinois under such contracts exceed $10,000 during the preceding 4
quarterly periods ending on the last day of March, June, September, and December. A retailer
meeting these requirements shall be presumed to be maintaining a place of business in Illinois but
may rebut this presumption by submitting proof that the referrals or other activities pursued within this
State by such persons were not sufficient to meet the nexus standards of the United States
Constitution during the preceding 4 quarterly periods. See 35 ILCS 105/2(1.1).

ST 17-0007-GIL
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THE SHARING ECONOMY
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).
Therefore, in the context of the provision of short-term accommodations that are rented
through the use of a third party platform, like Airbnb, the third party platform is not liable for HOOT.
Rather, the tax obligation is on the owner/host of the accommodations which are being rented.
COMPUTER SOFTWARE AND DIGITAL GOODS
Generally, retail sales or transfers of “canned” computer software are taxable in Illinois
regardless of the means of delivery. For instance, the sale or transfer of canned computer software
downloaded electronically would be taxable. However, if the computer software consists of custom
computer programs, then the sales of such software may not be taxable retail sales. See 86 Ill. Adm.
Code 130.1935(c). Custom computer programs or software must be prepared to the special order of
the customer.
Charges for updates of canned software are fully taxable pursuant to Section 130.1935. If the
updates qualify as custom software under Section 130.1935(c), they may not be taxable. If
transactions for the licensing of computer software meet all of the criteria provided in subsection
(a)(1) of Section 130.1935, neither the transfer of the software nor the subsequent software updates
will be subject to Retailers' Occupation Tax. A license of software is not a taxable retail sale if:
A) It is evidenced by a written agreement signed by the licensor and the customer;
B) It restricts the customer’s duplication and use of the software;
C) It prohibits the customer from licensing, sublicensing or transferring the software to a third
party (except to a related party) without the permission and continued control of the
licensor;
D) The licensor has a policy of providing another copy at minimal or no charge if the customer
loses or damages the software, or permitting the licensee to make and keep an archival
copy, and such policy is either stated in the license agreement, supported by the licensor’s
books and records, or supported by a notarized statement made under penalties of perjury
by the licensor; and

ST 17-0007-GIL
Page 6
E) The customer must destroy or return all copies of the software to the licensor at the end of
the license period. This provision is deemed to be met, in the case of a perpetual license,
without being set forth in the license agreement.
Please note that it is very common for software to be licensed over the internet and the
customer to check a box that states that they accept the license terms. Acceptance in this manner
does not constitute a written agreement signed by the licensor and the customer for purposes of
subsection (a)(1)(A) of Section 130.1935. To meet the signature requirement for an exempt software
license, the agreement must contain the written signature of the licensor and customer.
A license of canned software is subject to Retailers' Occupation Tax liability if all of the criteria
set out in 86 Ill. Adm. Code 130.1935(a)(1) are not met.
The Department does not consider the viewing and downloading of video, text and other data
over the internet to be the transfer of tangible personal property. Therefore, such viewing and/or
downloading activity over the internet would not be subject to liability under the Retailers' Occupation
Tax Act, Use Tax Act, Service Occupation Tax Act, or Service Use Tax Act. Please note, however,
the transfer of any canned software (or update of canned software) is considered the transfer of
tangible personal property and will be subject to Retailers' Occupation Tax and Use Tax liability,
regardless of the means of delivery. See 86 Ill. Adm. Code 130.1935(a). The transfer or sale of
canned software downloaded electronically would be taxable.
SERVICE PROVIDERS
The Illinois Retailers' Occupation Tax Act imposes a tax upon persons engaged in this State in
the business of selling tangible personal property to purchasers for use or consumption. See 86 Ill.
Adm. Code 130.101. In Illinois, Use Tax is imposed on the privilege of using, in this State, any kind of
tangible personal property that is purchased anywhere at retail from a retailer. See 86 Ill. Adm. Code
150.101. These taxes comprise what is commonly known as "sales" tax in Illinois.
Illinois Retailers' Occupation and Use Taxes do not apply to sales of service that do not involve
the transfer of tangible personal property to customers. However, if tangible personal property is
transferred incident to sales of service, this will result in either Service Occupation Tax liability or Use
Tax liability for the serviceman depending upon his activities. For your general information see of 86
Ill. Adm. Code 140.101 through 140.109 regarding sales of service and Service Occupation Tax.
CLOUD COMPUTING/SOFTWARE AS A SERVICE
Currently, computer software provided through a cloud-based delivery system – a system in
which computer software is never downloaded onto a client’s computer and is only accessed
remotely – is not subject to tax. The Department continues to review cloud-based arrangements. If,
after review, the Department determines that these transactions are subject to tax, it will only apply
this determination prospectively.
A provider of software as a service is acting as a serviceman. If the provider does not transfer
any tangible personal property to the customer, then the transaction generally would not be subject to
Retailers’ Occupation Tax, Use Tax, Service Occupation Tax, or Service Use Tax. If a provider of a
service provides to the subscriber an API, applet, desktop agent, or a remote access agent to enable
the subscriber to access the provider’s network and services, it appears the subscriber is receiving
computer software. Although there may not be a separate charge to the subscriber for the computer

ST 17-0007-GIL
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software, it is nonetheless subject to tax, unless the transfer qualifies as a non-taxable license of
computer software. If the provider is not otherwise required to be registered under Section 2a of the
Retailers' Occupation Tax Act and qualifies as a de minimis serviceman, the provider could elect to
pay Use Tax on its cost price of the computer software.
DROP SHIPMENTS
The Department’s regulations regarding Drop Shipments can be found at 86 Ill. Adm. Code
130.225. A drop-shipment situation is normally one in which an out-of-State purchaser (Purchaser)
makes a purchase for resale from a company (Company) which is registered with Illinois and has that
Company drop-ship the property to Purchaser’s customer (Customer) located in Illinois. For purposes
of this discussion, it is assumed that Purchaser is an out-of-State company that is not registered with
the State of Illinois and does not have sufficient nexus with Illinois to require it to collect Illinois Use
Tax. Company, as a seller required to collect Illinois tax, must either charge and collect tax or
document appropriate exemptions when making deliveries in Illinois. In order to document the fact
that its sale to Purchaser is a sale for resale, Company is obligated by Illinois to obtain a valid
Certificate of Resale from Purchaser. See 86 Ill. Adm. Code 130.1405 for the requirements of a
Certificate of Resale.
REFUND CLAIMS
Claims for credit and refunds are available when a person shows that he paid tax to the
Department as a result of a mistake of fact or law. Only the remitter of the tax erroneously paid to the
Department is authorized to obtain a refund. In order to obtain a credit, one must first demonstrate
that he or she has borne the burden of the tax erroneously paid (e.g. the tax was refunded to the
party who paid the tax). Claims for credit shall state the requirements that are contained in subpart (b)
of the regulation. See 86 Ill. Adm. Code 130.1501(b).
QUI TAM AND CLASS ACTION LAWSUITS
Pursuant to the Illinois False Claims Act, 740 ILCS 175, a private party acting as a relator on
behalf of the State, may bring a lawsuit against a taxpayer for underpaying sales tax. Further, Illinois
courts have recognized class action suits for recovery of wrongly paid taxes. See Geary v. Dominick's
Finer Foods, Inc., 129 Ill. 2d 389 (1989); Harrison Sheet Steel Co. v. Lyons, 15 Ill. 2d 539 (1959).
I hope this information is helpful. If you require additional information, please visit our website
at www.tax.illinois.gov or contact the Department’s Taxpayer Information Division at (217) 782-3336.

Very truly yours,

Cara Bishop
Senior Counsel

CB:bkl