Illinois Appellate Court
Civil Court
Administrative Procedure
Plaintiff appealed from trial court order finding that it had failed to exhaust its administrative remedies before filing a declaratory judgment lawsuit seeking a finding that it was not liable for unpaid taxes, interest, and penalties under the City of Chicago’s Property Lease Transactions Tax Ordinance. The appellate court affirmed, finding that because plaintiff’s lawsuit was not a facial constitutional challenge it was required to first exhaust its administrative remedies before seeking judicial relief. (HYMAN and COGHLAN, concurring)