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List of Forms by Chapter
Chapter 1 — Power To Tax
II. [1.2] Limitations Imposed by the Illinois Constitution on the Power To Tax
III. [1.42] Limitations Imposed by the U.S. Constitution on the General Assembly’s Power To Tax
IV. Limitations Imposed by Federal Statutes on the General Assembly’s Power To Tax and Limitations on Congress’ Power To Enact Such Legislation
V. [1.85] Limitations Imposed by Treaties on the General Assembly’s Power To Tax
Chapter 2 — Income Tax
I. Overview and History
II. The Tax Base
III. Allocation and Apportionment of Base Income
IV. Net Operating Losses
V. Taxable Years, Accounting Methods, Returns, and Notices
VI. Payment of Tax
VII. [2.122] Statutes of Limitation
VIII. Penalties and Interest
Chapter 3 — Sales and Use Tax
I. [3.1] Origins
II. Analysis of Retailers’ Occupation Tax
III. Analysis of Use Tax
IV. Analysis of Service Occupation Tax and Service Use Tax
Chapter 4 — Other Department of Revenue Taxes
II. [4.2] Motor Fuel Taxes
III. Utility Taxes
IV. Hotel Taxes
V. Taxes Relating to Motor Vehicles
VI. Taxes Relating to Tobacco, Liquor, Cannabis, and Controlled Substances
VII. Taxes Relating to Bingo, Charitable Games, Pull Tabs and Jar Games, Horse Racing, and Riverboat Gambling
VIII. Coin-Operated Amusement Device and Redemption Machine Tax
IX. Real Estate Transfer Tax
X. Taxes Relating to Aircraft and Watercraft
Chapter 5 — Department of Revenue Procedure
II. [5.2] Audit Procedure — Income, Sales, and Excise Taxes
III. Claims for Refund or Credit
IV. Protests and Prehearing Procedures with the Department of Revenue
V. Protest and Procedures Before the Illinois Independent Tax Tribunal
VI. [5.70] Other Protestable Events and Actions Requiring a Hearing with the Office of Administrative Hearings
VII. [5.75] Hearings Before the Department of Revenue
VIII. The Final Administrative Decision
IX. The Board of Appeals
X. Appendix — Board of Appeals and Tax Tribunal Forms
Chapter 6 — Department of Revenue Collections Bureau Units
II. Collections Bureau’s Enforcement Programs
Chapter 7 — Collection by the Department of Revenue in Court
II. Office of Attorney General
III. Referral of Collection Cases from Department of Revenue
IV. Action for Recovery of Taxes
V. Statute of Limitations
VI. Settlement and Compromise
Chapter 8 — Judicial Review in Matters Under $15,000
Chapter 9 — Illinois Independent Tax Tribunal
II. Jurisdiction
Chapter 10 — The Protest Act and Nonadministrative Remedies and Defenses
I. Introduction
II. General Background
III. [10.20] The Protest Act
IV. [10.36] Use
Chapter 11 — Other State Taxes
II. Secretary of State Franchise Taxes and License Fees on Foreign and Domestic Corporations
III. Department of Insurance — Privilege Tax, Surplus Line Producers, Fire Protection Fund
IV. [11.16] Illinois Commerce Commission — Gross Revenue Taxes
V. Attorney General — Estate and Generation-Skipping Transfer Tax
VI. Illinois Environmental Protection Agency — Hazardous Waste Fund and Hazardous Waste Research Fund
Chapter 12 — Unemployment Insurance
I. Introduction
II. Liability Under the Unemployment Insurance Act
III. Wages
IV. Experience Rating
V. Contributions and Payments in Lieu of Contributions
VI. Protests on Assessments and Refunds
VII. Hearings on Assessments and Refunds
VIII. Collections
IX. Miscellaneous Provisions
Chapter 13 — Local Government Taxes
I. [13.1] Basis of Local Taxing Power
II. [13.4] Types of Local Governmental Entities That Levy Taxes
III. [13.8] Types of Taxes Imposed by Local Governmental Units
IV. Powers of Taxing Bodies in the Collection of Taxes
V. Assessment of Taxes
VI. [13.57] Procedures To Follow if Under Local Government Audit
VII. [13.61] Procedures To Follow if Assessed by a Local Governmental Body
VIII. [13.68] Hearings at the Local Government Level
X. [13.75] Enforcement Actions of Local Government
XI. [13.79] Refunds of Overpayments of Local Taxes
Chapter 14 — Unclaimed Property
I. Introduction to Unclaimed Property
II. Selected Issues in Unclaimed Property: A Closer Look
III. [14.39] Unclaimed Property Audits
IV. How To Limit Your Liability
Chapter 15 — Miscellaneous Issues Affecting State and Local Taxes
I. [15.1] Bankruptcy
II. [15.8] Taxpayers’ Bill of Rights
III. [15.12] The License-Hold Dilemma
V. [15.16] Preemption
VI. [15.21] Filing/Remittance with the Appropriate Taxing Body
VII. [15.27] Amnesty and Voluntary Disclosure Programs
XIV. The RepresentativesPaul S. Caselton is a Visiting Associate Professor at the University of Illinois Springfield. He was previously Deputy General Counsel, Income Tax Division, for the Illinois Department of Revenue in Springfield. His article, Lost Profits Damage Awards Under UCC Section 2-708(2), appeared in the Stanford Law Review. Mr. Caselton received his B.A. in finance magna cum laude from the University of Illinois and his J.D. from Stanford Law School.
Michael R. Coveny is an administrative law judge with the Illinois Department of Revenue in Chicago. Prior to joining the Department’s legal staff, he served for over 18 years as an Assistant Attorney General in the Revenue Litigation Bureau in the Office of the Illinois Attorney General in Chicago. Coveny is a CPA and a Past Chair of the Chicago Bar Association’s State and Local Tax Committee. He received his BBA from the University of Notre Dame and his JD and LLM (Taxation) from the Chicago-Kent College of Law.
C. Eric Fader is special counsel at Duane Morris LLP in Chicago, where he concentrates his practice on tax law. Fader was a 2025 recipient of the Illinois CPA Society Distinguished Service Award, was Chair of the Illinois CPA Society’s State Tax Committee, was formerly President of the Illinois CPA Society’s Fox Valley Chapter, and is a trustee for the Taxpayers’ Federation of Illinois. Fader graduated from DePaul University College of Law, where he served as executive editor of the DePaul Business Law Journal.
Jordan M. Goodman is a Partner and co-leader at Kilpatrick Townsend & Stockton LLP in Chicago, where he concentrates his practice on resolving complex state and local tax controversies for Fortune 1000 corporations and wealthy families. He has been listed by Chambers: USA Guide and Leading Lawyers as a leading lawyer in tax controversy and has been recognized in The Best Lawyers in America publication. Goodman received his BA from Indiana University and his JD from the University of Illinois College of Law.
David A. Hughes is a Partner at Kilpatrick Townsend & Stockton LLP in Chicago, where he concentrates his practice on state and local tax area. He is Vice Chair of the American Bar Association’s State and Local Tax Committee, an adjunct professor at the Northwestern Pritzker School of Law, and a fellow at the American College of Tax Counsel. Hughes received his BA from the University of Notre Dame and his JD from the Columbia University School of Law.
Thomas A. Jaconetty, a sole practitioner in Chicago, is a member of the Chicago, Illinois State, and American Bar Associations; the Justinian Society of Lawyers; and the Advocates Society. He retired from 38 years of government service as Deputy Assessor of Valuation and Appeals for the Cook County Assessor and previously as Commissioner, Chief Deputy Commissioner, and First Assistant Commissioner for the Cook County Board of Review. A Fellow of the International Association of Assessing Officers, Jaconetty chaired its Legal Committee ten times. A long-standing member of the ISBA State and Local Taxation Section Council, he is a Past Chair of the National Conference of State Tax Judges. Since 1985, Jaconetty has presented papers or moderated programs at 165 real estate tax seminars in 30 cities across U.S. and Canada, sponsored by some 20 professional organizations, and has authored more than 20 articles. Jaconetty received his BA with honors and summa cum laude from Loyola University of Chicago and his JD from the Northwestern University Pritzker School of Law. An adjunct professor in the UIC-Law LLM Program, he has guest lectured at the DePaul University College of Law, the University of Illinois, and the Lincoln Institute of Land Policy. Jaconetty regularly judges the Northwestern and National Appellate Advocacy Moot Court Competitions, mentors high school and middle school student history research projects, and sits on the boards of Regina Dominican High School and the Weber High School Alumni Association.
Stanley R. Kaminski is a Partner at Duane Morris LLP, in Chicago, where he concentrates his practice in areas of multi-state and local tax law, including sales/use tax, franchise tax, corporate income tax, and individual income tax issues. Mr. Kaminski is a Former Chair of the State and Local Tax Committee of the Chicago Bar Association and a twice Former Chair of Illinois State Bar Association's State and Local Tax Section Council, as well as coeditor of the ISBA’s State and Local Tax Section Council’s Tax Trends newsletter. He is a CPA and an adjunct professor of law at DePaul Law School. Mr. Kaminski received his B.S.C. with highest honors from DePaul University College of Commerce and his J.D. from DePaul University College of Law.
Dana Deen Kinion is an instructor at the University of Illinois Springfield and a board member at the Property Tax Appeal Board in Springfield. She is a former associate counsel in both sales tax and income tax at the Illinois Department of Revenue. She is also a Past Chair of the Sangamon County Board of Review. Kinion received her BA from Texas A&M University, her JD from the University of Tulsa College of Law, and her LLM (Taxation) from Southern Methodist University.
David J. Kupiec is Managing Partner of Kupiec & Martin, LLC, in Chicago, where he concentrates in state and local taxation. Kupiec is a member of the Illinois State Bar Association’s State and Local Tax Section and has held various positions in that Section, including Chair, Vice Chair, Associate Editor, and Continuing Legal Education Coordinator. He is also a member of the Illinois Taxpayers’ Federation Income Tax Committee, where he has been Chair and a Board Member. He is a CPA and an adjunct business law instructor at Loyola University Chicago Quinlan School of Business. Kupiec received his BBA from Loyola University of Chicago and his JD from the Chicago-Kent College of Law.
David W. Machemer is an associate at Horwood, Marcus & Berk Chartered, in Chicago, and concentrates his practice in state and local tax matters. Mr. Machemer is a member of the Council on State Taxation and the Chicago Bar Association. He received his B.A. from Michigan State University and his J.D. from The John Marshall Law School.
Natalie M. Martin is a Partner at Kupiec & Martin, LLC, in Chicago, where she concentrates her practice in state and local tax law. Martin is a member of the Taxpayers’ Federation of Illinois and the Illinois Chamber of Commerce Tax Institute. She is Past Chair of the Chicago Bar Association’s State and Tax Committee. Martin received her BS from the University of Illinois and her JD from the Chicago-Kent College of Law.
Julie-April Montgomery was an administrative law judge with the Illinois Department of Revenue for almost six years, Deputy Director for the Cook County Department of Revenue for three years, and a senior attorney in the Tax Group of the City of Chicago’s Law Department for eighteen years. She previously served as the local government liaison to the State and Local Tax Committee of the Chicago Bar Association, Associate Editor of the State and Local Tax Committee of the Illinois State Bar Association, member of the Illinois CPA Society’s State and Local Tax Committee, and the first female Vice Chair and Chair of the State and Local Tax Committee of the Chicago Bar Association. She was also in the Inaugural Class of the “Centennial Society” of the Chicago Alumni Chapter of Phi Alpha Delta Law Fraternity, International. Ms. Montgomery received her B.S. from the University of San Francisco, her M.B.A from Roosevelt University, and both her J.D. and LL.M. in Taxation from New York University, School of Law.
Gregory J. Ramel, Sr., was First Deputy Legal Counsel for the Illinois Department of Employment Security in Chicago, where he practiced in unemployment insurance. He substantially revised and rewrote the introductory essay on the Illinois Unemployment Insurance Act for SMITH-HURD ILLINOIS ANNOTATED STATUTES. Ramel is a member of the Chicago and Illinois State Bar Associations and is a member and Past President of the Advocates Society. He has also taught at both Valparaiso University and Northeastern Illinois University. Ramel received his BA from DePaul University, his MA from the University of Chicago, and his JD from the DePaul University College of Law.
Jennifer C. Waryjas is Of Counsel at Jones Day, in Chicago, where she focuses her practice on state and local tax and unclaimed property. She is a Past President and Secretary of the Unclaimed Property Professionals Organization. She is also the Income Tax Co-Chair for the Institute for Professionals in Tax Annual Conference and a former Chair of the Income Tax Symposium. Waryjas received her BA from Illinois Wesleyan University and her JD from the University of Illinois College of Law.
Douglas A. Wick is an associate at Reed Smith LLP, in Chicago, where he concentrates in state tax. Mr. Wick is Vice Chair of the State and Local Tax Committee of the Chicago Bar Association and was an extern for the Honorable Dale S. Fischer of the U.S. District Court, Central District of California. He received his LL.M. (taxation) from New York University, where he received the David F. Bradford Memorial Prize for best tax paper; his J.D. from the University of Southern California; and his B.S. from Illinois State University.
Kevin J. Wolfberg is a Partner with Schain, Banks, Kenny & Schwartz, Ltd., in Chicago, where he practices in the areas of government relations, state and local taxation, land use, zoning, economic incentives, and municipal law. Mr. Wolfberg is an adjunct professor at The John Marshall Law School, where he teaches state and local taxation, and is a member of the Illinois and Chicago Bar Associations, the Chicagoland Chamber of Commerce, and the Taxpayers Federal of Illinois. He received his B.A. from Indiana University and his J.D. and LL.M (Taxation) from The John Marshall Law School.
Michael J. Wynne is Of Counsel at Jones Day in Chicago, where he concentrates his practice on state tax litigation. He is a member of the Executive Committee at the Taxpayers’ Federation of Illinois and was named State Tax Author of the Year in 2018 and 2024 by Bloomberg Tax. Wynne received his BS from Southern Illinois University and his JD from the University of Illinois Chicago School of Law.
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