Christopher Walter Pautsch, Petitioner,

v.

Illinois Department of Revenue, Respondent.

ILLINOIS INDEPENDENT TAX TRIBUNAL

) ) ) ) ) ) ) )

PETITION

0ECEIVEn n A~rG ® J 2m6 u BY:------

I~ -rr t .r.J

The Petitioner, Christopher Walter Pautsch, on July 30th, 2016, hereby petitions the Illinois Independent Tax Tribunal to review and reverse and/or modify the [Notice of Tax Liability, Notice of Deficiency, Notice of Claim Denial, Notice of Penalty Liability, etc.] ("Notice") issued by the Illinois Department of Revenue ("Department"), for the reasons stated below:

INTRODUCTION

1. The "Notice" was issued by the Department on May 12, 2016 as a Notice oflntent to Levy Petitioner's Assets in the amount of$41480.00 in tax, $16533.92 in penalties and $13557.69 in interest, with payments of$24795.65 providing a sum due of$46775.98 for taxable periods Feb 29,2008 thru July 31,2009. A copy of the "Notice" NPL PENALTY ID 11338148 is attached to this Petition. 2. Petitioner, Christopher Walter Pautsch, an officer of the LLC, is an individual, with the LLC's principal place of business in Elk Grove Village, Illinois. The LLC was registered as Christopher Michaels Fine Carpets & Floors, LLC. The LLC was located at 1001 Arthur Ave Elk Grove Village, IL 60007, and its telephone number is non-existent. The LLC Taxpayer Account number is 5536-6112. The LLC was involuntarily dissolved on October, 2010 The Petitioner resides at 41 W260 Prairie View Ln Elburn, IL 60119 and his telephone number is 224-355-5446. The Petitioner's account is 337403458. 3. Summary Basis of Petition:

a) Petitioner is no longer a partner of Christopher Michaels Fine Carpets & Floors, LLC., as his 50% interest in the company was acquired by Macy's Inc. during Petitioner's bankruptcy proceedings; therefore, making Macy' s responsible for taxes due.

b) During 2008 & 2009, the period from which taxes are due, Macy' s paid vendors directly for material; therefore, responsible for such USE taxes.

c) Macy' s always directly collected the customer's monies; therefore, they are responsible for USE taxes. Their distribution of monies due was not on a timely basis, breaching the contract and a basis for the lawsuit.

d) When Petitioner went through Chapter 7 bankruptcy, case # 11-46250 with the final report filed 8/13/2015, $17,804.65 was paid to the Illinois Department ofRevenue from

Petitioner's assets. In reviewing that action, Petitioner claims the $17804.65 was not due by him and should be collected from Macy's for all of the aforementioned reasons.

BACKGROUND AND RELEVANT FACTS

4) Petitioner is not a partner of Christopher Michaels Fine Carpets & Floors, LLC, any longer. 5) When Petitioner was forced to file personal bankruptcy, his 50% ownership of the company

was acquired by Macys, Inc. since the bankruptcy Trustee viewed the lawsuit as an asset of Petitioner. This was done by Macy' s to reduce their exposure in a very good lawsuit Petitioner and partner Michael Dickmann had against them for withholding funds; therefore, forcing closure of the company due to insufficient capital. It was viewed by all as an appalling action by Macy' s since they are the ones who caused the failure of the company. It was equally viewed as a failure to perform his fiduciary responsibility of the bankruptcy Trustee to settle a $7MM lawsuit for $25k. As a result, Petitioner had no way to recoup the loss of his home and millions invested.

6) 50% of the company is owned by Michael Dickmann, president of the company, 155 Richard Ct. Addison, IL 60 101 and with whom Macy' s later settled the suit for a meager sum although the suit was for $7MM. The settlement was forced since he had no way of funding the proceeding of the lawsuit.

7) During 2008 & 2009, the period from which taxes are due, Macy's paid vendors directly for material; therefore, responsible for such USE taxes.

8) Macy's always directly collected the customer's monies through their point-of-sale system; therefore, they are responsible for USE taxes. Their distribution of monies due was not on a timely basis, breaching the contract and a basis for the lawsuit.

9) When Petitioner went through Chapter 7 bankruptcy, case# 11-46250 with the final report filed 8/13/2015. In that filing, $17,804.65 was paid to the Illinois Department of Revenue from Petitioner's assets. In reviewing that action, Petitioner claims the $17804.65 was not due by him and should be collected from Macy's for all of the aforementioned reasons.

10)Lastly, as a result of this bankruptcy, all Petitioner's assets were acquired by the court with the exception of one 20 11 automobile which Petitioner was allowed by law to keep. Petitioner is 67 years old, does not work, lives off Social Security and resides with his son at the address provided. So, there's nothing more the government can take from him -you have it all.

11) Due to Petitioner's financial condition, he requests the $500 filing fee be waived. A Net Worth statement is attached as Exhibit F.

12) Macy' s Inc. and Michael R. Dickmann should have been included in the tax collection process from the very beginning rather than pursuing Petitioner who is not responsible for such taxes.

13) Exhibit A is the Illinois Department of Revenue Collection Action Notice of Intent to levy assets from Jennifer Thomas Rockford Office.

14) Exhibit B is Petitioner's response to Jennifer Thomas. In a telephone conversation, after conferring with her supervisor, she instructed me to file a petition with the Board of Appeals

to rehear my case. She further stated that no collection activity would take place soon. Both statements were not true since the BOA was not the proper venue and monies have been taken from my bank account this last week

15)Exhibit Cis the Board of Appeals petition.

16) Exhibit Dis the Board of Appeals response indicating they had no jurisdiction and Petitioner should request a Discretionary Rehearing from the Administrative Hearing Division, dismissing the case. No contact information to proceed was provided.

17) After hours of searching, Petitioner found the Chief Administrative Law Judge, Terry D. Charlton, and submitted the aforementioned exhibits to the office of Administrative Hearings of the Illinois Department of Revenue. Exhibit E is their response GRANTING a Late Discretionary Hearing. Finally, after months of wasted time and energy, the right person was found and this document is therefore presented.

18)Exhibit F is the Petitioner's Net Worth statement.

APPLICABLE LAW

19) Petitioner is no longer an owner of the Christopher Michaels Fine Carpets & Floors, LLC. 20) Due to Macy' s Inc. actions of acquiring Petitioner's ownership, they are responsible for any taxes

due. 21) Since Macy' s paid directly for goods during the tax period due and always directly receiving

such monies via their point-of-sale system for goods sold, Macy's Inc. is responsible for all taxes due.

22) Macy' s Inc. and Michael R. Dickmann should have been included in the tax collection.

CONCLUSION AND RELIEF REQUESTED

WHEREAS, Petitioner requests that the "Notice" be cancelled for the reasons contained herein and be absolved of any monies due. Furthermore, Illinois Department of Revenue Rockford Office, Jennifer Thomas, should be instructed to cease all actions against Petitioner and return all funds

alreadY. g ishediup.jft /21i 1sto r Walter Pautsch

41 W26 rairie View Ln Elburn, Illinois 60 119 224-355-5446

July 30th, 2016

Collection Action Notice of Intent

CHRISTOPHER W. PAUTSCH 41W260 PRAIRIE VIEW LN ELBURN IL 60119-8807

Mt~tA f . . ·~l STATE OF

May 12,2016

\_ _____ ::· II i no is DEPAATMENT OF REVENUE W tax.lllinols.gov

11111111111111111111111~1111111111111111111111111111111111111~ LetteriO:L0714630928

Taxpayer 10: .XXX-.XX-3458 NPL Penalty 10: 11338148

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- CHRISTOPHER MiCHAELS FINE CARp-41W260 PRAIRIE VIEW LN ELBURN IL 60119-8807

Demand for Payment

We intend to issue a levy against your assets unless you pay us.

You must pay us $46,775.98 by June 2, 2016. If you do not, we intend to issue a levy for this amount against your assets without further notice to you.

A levy means we can, by legal authority, take your assets held by someone else. Examples of assets we may levy include your wages, contractual payments, bank accounts, and accounts receivables.

The fol!owing pages detail the items that need your immediate attention.

If you have any questions about this notice, please contact us immediately at the address and phone number listed below.

JENNIFER THOMAS ILLINOIS DEPARTMENT OF REVENUE 200 SOUTH WYMAN STREET SUITE 306 ROCKFORD IL 61101-1237

815 987-7494 815 987-7474 fax

IDOR-4-NLEV (R.Q3/14)

For information about __ ~----- _> l!~yv tQ_pay_~ ___ _

> what you owe > collection actions

P-000113

!T~~~~~j-~_~f~!s collection action Pay

To pay, you may use one of the following options.

1) Pay us using the "check by phone" method by calling us at the phone number on the front of this letter. You will need your check number, account number, and bank routing number, and we will prepare a check to submit to your financial institution.

2) Mail us your payment in the enclosed envelope. Your payment should be guaranteed (i.e. cashier's check, money order) and made payable to the Illinois Department of Revenue.

3) If you cannot pay the entire amount you owe at this time, you may be considered for an installment payment plan. You must apply for a payment plan on Form CPP-1, Installment Plan Request. Go to tax.illinois.gov, or call or write us for forms or more information. We will let you know if your request is approved.

File Returns and Pay

To file any returns listed in this letter, you must send us your completed returns in the enclosed envelope. You must also pay us any amount due on these returns.

Federal Bankruptcy Court

If you are currently under the protection of the Federal Bankruptcy Court, contact us and provide the bankruptcy number and the bankruptcy court. The bankruptcy "automatic stay" does not relieve your obligations to file tax returns.

Correct our records

If our records are not correct, send us proof of your prior payment, a copy of the return you filed, or other documentation so that we can correct our records.

35 ILCS 5/1109 of the Income Tax Act and 35 ILCS 120/5f of the Retailers' Occupation Tax Act authorize this levy. 735 ILCS 5/12-803 of the Code of Civil Procedure and federal law {15 U.S.C. 1673) define "maximum wages subject to collection." More information is on our website tax.illinois.gov.

• You have the right to call the Illinois Department of Revenue for help in resolving tax problems.

• You have the right to privacy and confidentiality under most tax laws.

• You have the right to respond within specified time periods to our notices by asking questions, paying the amount due, or providing proof to refute our findings.

• You have the right to appeal our decisions in many instances within specified time periods by asking for our review or by taking the issue to court.

• If you have overpaid your taxes, you have the right to a credit {or, in some cases, a refund) of that overpayment, · within certain time periods.

The full text of the Taxpayers' Bill of Rights is contained in the Illinois Compiled Statutes, 20 ILCS 2520/1 et seq.

IDORo4·NLEV (R-03114) IDOR-4-NI FV ,f< n,,l4l

For more information about these rights and other departmental procedures, visit our Web site at tax.illinois.gov or contact us at the address or telephone numbers below.

Call: 1 800 732•8866 -· 1 217 782-3336 1 800 544-5304 (TOO-telecommunications device for the deaf)

Write: ILLINOIS DEPARTMENT OF REVENUE PO BOX 19044 SPRINGFIELD IL 62794-9044

Collection Action Notice of Intent

CHRISTOPHER W. PAUTSCH 41W260 PRAIRIEVIEWLN ELBURN IL 60119-8807

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May 12,2016

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\_~--- llinois DEPARTMENT OF REVENUE ~-J tax.illinois.gov

111111111 Ill 1111111111 111111111111~1 IIIII IIIIIIIIIIIIHIIIIIIHI LetteriO:L0714630928

Taxpayer 10: NPL Penalty 10:

XXX-XX-3458

11338148

This SfaTementlisfs our mostrecentinformationabout your unpaid balance, avaifable-credtt-s, or returnsyou-fl-ave not-ftfed.

'- '~ . ._. -~·-·~· ·- -- -·~------ - "''-<•• -'··--- ----·-· -~ ·-

Sales/Use Tax & E911 Surcharge Account 10: 5536-6112

Period Tax Penalty Interest Other Payments/Credits Balance

29-Fe~2008 1,656.00 228.72 11.61 0.00 (1,667.61) 228.72

31-Mar-2008 1,637.00 226.44 6.10 0.00 (1,643.10) 226.44

31-May-2008 3,698.00 473.76 11.14 0.00 (3,709.14) 473.76

30-Jun-2008 2,653.00 1,236.72 1,124.98 0.00 (3,218.14) 1,796.56

31-Jul-2008 2,653.00 1,236.72 1,103.18 0.00 (3,196.34) 1,796.56

31-Aug-2008 2,653.00 1,236.72 1,079.20 0.00 (3,172.36) 1,796.56

30-Sep-2008 2,653.00 1,236.72 1,058.86 0.00 (3,152.02) 1,796.56

31-0ct-2008 2,653.00 1,236.72 1,036.34 0.00 (3,129.50) 1,796.56

30-Nov-2008 2,653.00 1,236.72 1,058.08 0.00 (1,907.44) 3,040.36

31-Dec-2008 2,653.00 1,236.72 1,152.02 0.00 0.00 5,041.74

31-Jan-2009 2,653.00 1,236.72 1,129.50 0.00 0.00 5,019.22

28-Feb-2009 2,653.00 1,236.72 1,109.16 0.00 0.00 4,998.88

31-Mar-2009 2,653.00 1,236.72 1,086.62 0.00 0.00 4,976.34

30-Apr -2009 2,653.00 1,236.72 1,064.82 0.00 0.00 4,954.54

30-Jun-2009 2,653.00 1,236.72 1,023.42 0.00 0.00 4,913.14

~Jui=2009- 2,o::>;;,.OO--~- 7o4.36--~ ---suz.-88 --~~-- -{};30- --._._,_.,. ..--...... __ ......... __ -&.00-- -3;92!HM

Total Balance: 46,775.98

IDOR-4-NLEV (R-03114)

P-000114

To: Jennifer Thomas

Illinois Department of Revenue

200 South Wyman Street Suite 306

Rockford, IL 61101-1237

RE: Taxpayer ID: 337-40-3458 Christopher W. Pautsch

NPL Penalty ID: 11338148

Account ID: 5536-6112

Dear Ms. Thomas,

I went through Chapter 7 bankruptcy, case# 11-46250 with the final report filed 8/13/2015. In that filing,

$17,804.65 was paid to the Illinois Department of Revenue to settle all amounts due by me to the state.

Furthermore, as part ofthis proceeding, my 50% ownership was sold to Macy's. Macy's purchased my

ownership since the bankruptcy Trustee deemed it an asset and we had a lawsuit against Macy's for $7MM

and subsequently they would reduce their exposure in the lawsuit by 50%. As a consequence of that action, I

have no interest or responsibility for Christopher Michaels Fine Carpets & Floors, LLC., whatsoever.

Currently, 50% is owned by Macy's and 50% is still originally owned by Michael R. Dickmann 155 Richard Ct.

Addison, IL 60101, who was the President of Christopher Michaels Fine Carpets & Floors, LLC.

As a further point of contention, I see a fixed amount of $2653 monthly from June 2008 through July 2009, yet

there are payments of varying amounts. This doesn't make sense. Please clarify.

Furthermore, during 2008 and 2009, Macy's took over responsibility for paying vendors for product since we

were in financial difficulty (caused by Macy's) so they would be responsible for USE TAX. Also, sales monies

were always collected from customers by Macy's.

Lastly, as a result of this bankruptcy, all my assets were acquired by the court with the exception of one 2011

automobile which I was allowed to keep by law. I am 67 years old, do not work and live off Social Security and

reside with my son at the address provided. So, there's nothing more the government can take from me- you

have it all.

Please respond so I know this have been resolved regarding my involvement.

Thank You,

Christopher W. Pautsch

41W260 Prairie View Ln

Elburn, IL 60119

224.355.5446

Illinois Department of Revenue

BOA-1 Board of Appeals Petition Docket no.

Read this information first Do not write above Ulls rme.

Everyone must complete Parts 1, 3, 4, and 5. Complete Part 2 if someone will represent you. If you do not answer each question completely and truthfully, the Board of Appeals may reject your petition. If you need more space, please attach additional pages.

Part 1: Identify yourself, y siness, or your organization

1 Taxpayer's name L.d'Ur,'..L2~!.!!::1r4.-LL!.:.tf73".!..!.....::3"C~f/~ 4

6

7

8

9

IBTno. illlnolsbusmess ~ num&er

Exdse~no .. __________________________ __

FAXno.l__j, ____ ~--------~----~----

Emai~ address CI<Jf/4ti75Cl/@6/J1AIL· C'PJ Part 2: Identify your tax representative If you are being represented by someone else, this part must be completed in full. Please note: Your representative must attach an executed Form IL-2848, Power of Attorney, to this petition.

1 Representative's name 3 Phone no. (work)L_) ___________ ~

2 Street address ~-----------~ 4 FAXno.l__j~---------------------

City, state, ZIP 5 Email address

Part 3: Provide the following information 1 I' 71 /t ~ /'. 1 write the name of the person who referred you to the Board of Appeals deJ?I) lf"r 1/M//JitS.; / L t:rp:Lu/& 2 Identify the type of tax for which you are requesting relief. list specific assessment numbers or liability periods. Attach

correspondence from us listing your liability. t( ~E 7ifX, /tJ PL /)e,14~ / D / J? ?JS /'/f

3 You must check one of the following. You may request relief from penalties or interest (or both) based on reasonable cause; or if you are unable to pay the full amount due under any circumstances, you may offer an amount in compromise.

}8[ This petition is a request for abatement of penalty or interest (or both) based on reasonable cause. The following is the type and amount of penalty or the amount of interest (or both) I am requesting to be waived.

Type and amount of penalty relief ______ ~----___,,.......,--""%""~----.,........,----==---

Amount of interest relief$.________ /tlflfL /J.ehe/Je1cl't5/l?7 ~V; 7 7S: 7! or 0 This petition is an offer in compromise due to my inability to pay the full amount due under any circumstances.

This is my best possible offer$ . 0 lump sum 0 Request a pay plan (describe)

If you are making an offer in compromise, you must attach complete copies of the following: your last three federm and state income tax retums and an schedules, barnk statements from all of your bank acoounts summarizing the last six months' activity, a current financial statement (BOA-4, Financial Information for IndividUals, or BOA-5, Financial information for Businesses , and co ies of our last two a check vouchers.

BOA-1 (R-1101) Thb f1nm i3 mlll!mlm!l es ou!lillSZl by Cltapl<:r 127, SC!l&m 3!!h2ll, a! 11ID Civil Admin-o Cede a! l!:lr~ llico!o!;uro a! lrf.mm::!fum en lfOi.lll'«ARY. Falluro to provllla lnf!umatilm cmM r=lt fn i$cllan o1 ycur ~. Tltis fnmb ilro balm <lJillfllVIlll by f.lw Fcmm Mmlligmmm1 Ccnmr. il..-432-.1501

4 Are you requesting that the Board Chainnan issue a temporary restraining. order (TRO), to stop the department from enforcing collection, until the board has reviewed you!' petition and made a decision in your case? (Please note, the iss~.n­~ of a TRO is at the discretion of the Chairman of the Board). A yes ;:] no

If you answ~ "yes," have you paid the tax p_ortion of the specific assess_rents at lzue? _ _/l ~ yes ~ no P/tK7711-L f; 17 io~ ~ G" rtdl Prrnn Y?/1~~ ~roeexu:e;fjf

5 H_ave you p~ously petitioned the Board of Appeals for relief? . {I -~ , yes .)'! no

1 Tell us if you have been contacted by any of the following program areas within the illinois Department of Revenue and if you are involved in any of the following proceedings. (Check all that apply.)

0 Administrative hearings M Collections (Department hearing before administrative law judge) f'

~ Bankruptcy no. //-Lj(pJ.. 6{) 0 Collections with Attorney General's Office

0 Audit

0 100 percent penalty

0 Garnishment of wages

0 Bank levy

0 Revocation of liquor license

U Revocation of certificate of registration

D Revocation of professional license

8 You must answer this question only if this petition is on behalf of a business.

When did you first begin business activity in Illinois? ~-'~_I ___ _ IV'.nnlh Cay Year

DesC!ibe your principal business activity.

Page 2

.-- - ---1\

8 (continued) If your business is a closely held corporation or partnership (having fewer than 10 shareholders or partners), list a!l corpo­rate shareholders or partners, and write the address and Social Security number for each.

- ------ ---~

- ----------

- -----===- ------

9 :~o y:a~ own~ h:e you owned any nonpublicly traded business doing business in Illinois within the last 10 years?

If you anS\.'Vered "yes." write the business name, the business address, the time period during which you owned the busi­ness, the principal business activity, federal employer identification number, and any appropriate Illinois business tax numbers.

Do any of these businesses currently have outstanding Illinois tax liability? Dyes Dno

10 The Board of Appeals will decide your case based upon your written petition and supporting documentation. The board wiii also grant you a hearing to discuss your petition if you so desire.

Are you requesting a hearing at the Board of Appeals? }( yes 0 no

If you answered "yes," indicate where you are requestin~ that the hearing be conducted.

}( Chicago 0 Springfield

If you have travel limitations, please explain.

BOA-1 (R-1/01)

Part 4: Taxpayer or petitioner must sign below

i state that I have examined this petition and, to the best of my knowledge, it is true, correct, and complete.

Date:/L_§ ,0)_ 1_2#/ b~ wamm 11ay ~7

Part 5: Sign the waiver

Explanation of waiver: Before the Board of Appeals accepts jurisdiction, the following waiver of statutes of limitations must be signed by the petition­ing taxpayer personally, by a duly authorized officer of a petitioning corporation, or by a taxpayer's representative under a valid power of attorney. This waiver will be valid only if the Board of Appeals accepts jurisdiction in this case. If the board accepts jurisdiction, a docket number will be assigned, and this waiver will be executed by the board on behalf of the Department of Revenue. The waiver affects open periods only, having no effect on closed periods, or periods for which assessments have been issued and for which the liability is final.

Waiver of Statute of Limitations

In order to allow time to review the taxpayer's petition for re~ief by the Illinois Department of Revenue Board of Appeals, the undersigned expressly agrees to extend the running of any and all statutes of limitations regarding the collection of any tax, penalty or interest for the periods of time in which the petition is being considered by the Board. This waiver applies only to collections action, and in no way is meant to reopen any periods or collections activities barred by the passing of any previously expired statutes of limitations.

'- /()Jl (It;_ Taxpayer's representamre's signature ('if duly aumonzed under power of attorney}

Illinois Department of Revenue:

Director of Revenue

Send the original petition, a copy of the petition, notices of deficiency/tax liability, and relevant documents. If this petition is an "offer in compromise," include copies of your last three federal and state income tax returns and all schedules, bank statements from all of your bank accounts summarizing the last six months' activity, a current financial statement (BOA-4, Financial Infor­mation for Individuals, or BOA-5, Financial lnfonnation for Businesses), and your last two paycheck vouchers.

Mail to:

Page 4

ILLINOIS DEPARTMENT OF REVENUE BOARD OF APPEALS JAMES R THOMPSON CENTER 100 W RANDOLPH ST SUITE 7-339 CHICAGO ll 60601-327 4

Questions? Call: 312 814-3004 weekdays between 8:30a.m. and 5:00p.m. Fax: 312 814-3055

BOA-1 (R-1/01)

CHRISTOPHER PAUTSCH 41W260 PRAIRIE VIEW LN ELBURN IL 60119-8807

lllllllllllllll~ IIIII IIIII ~111111111111111111 IIIII m11111 101 Letter 10: L 1645469328

Taxpayer 10: Petition type:

Docket no.:

XXX-XX-3458 Reasonable Cause 16-0892

The Board of Appeals has examined the administrative record and finds no basis for jurisdiction. Petitioner is requesting that the Board review the validity of the corporate officer Notice of Penalty Liability assessment and the Board of Appeals does not review such cases. Petitioner should request a discretionary rehearing with the Administrative Hearings Division. There being no other issue before the Board of Appeals, this matter is dismissed.

Case Dismissed

?S~tAJ~ Brian L. Wolfberg ;fj Chairman, Board of Ap::

Date ls~ued

IDOR-7-BOA11 (N-07115)

Christopher W. Pautsch 41W260 Prairie View Lane Elburn, IL 60119

Illinois Department of Revenue OFFICE OF ADMINISTRATIVE HEARINGS

Willard lee Building 101 West Jefferson Street- Level SSW

Springfield, IL 62702 (217)782-6995

July 11,2016

Re: Late Discretionary Hearing Granted- Tribunal Jurisdiction Account ID: 5536-6112 Christopher Michaels Fine Carpets & Floors Collection Action dated February 23, 2010 NPL Penalty ID: 11338148

Dear Mr. Pautsch:

The office of Administrative Hearings of the Illinois Department of Revenue received your request for a late discretionary hearing regarding the above Notice of Penalty Liability. Based on the information provided in your request, I believe that it is appropriate to grant your request for a late discretionary hearing for the above Notice.

The amount of liability at issue for this protest exceeds the statutory amount for which the Department has jurisdiction. For late discretionary hearings that are granted and that exceed the statutory amount, jurisdiction is vested solely in the Illinois Independent Tax Tribunal (Tax Tribunal). See 35 ILCS 1010/1-1 et seq.

The Tax Tribunal's rules provide that when a late discretionary hearing is granted and the protest meets the statutory amount, the taxpayer shall file a petition with the Tax Tribunal within 60 days and shall attach a copy of the letter granting the late discretionary hearing.

I recommend that you review the information provided on the Tax Tribunal's website (www.illinois.gov/taxtribunal) and contact them if you have any questions.

erry . Charlton Chief Administrative Law Judge

TDC:vs