Plaintiff is a nonresident corporation and foreign to Illinois, and operates its business in and earns income in Illinois. Department of Revenue issued a notice of denial, denying claimed deductions, and 2 notices of deficiency. Plaintiff filed protest, and matter went to administrative hearing.The correct amount of interest income Plaintiff earned as a partner in certain accounts was an evidentiary prerequisite necessary to rebut the Department of Revenue's prima facie case, but that amount was absent from Plaintiff's books and records presented at administrative hearing.Plaintiff estimated the total interest income realized and factored it into a calculation, to arrive at an estimation of nonbusiness interest income earned for taxable years in question. Court affirms decision of Director of Department of Revenue that Plaintiff failed to establish with competent evidence the amount of interest income earned to prove its entitlement to nonbusiness interest deductions claimed on its amended tax returns. (PIERCE and WALKER, concurring.)
Illinois Appellate Court
Civil Court
Corporate Tax