Pepsico, Inc. v. Department of Revenue

Illinois Appellate Court
Civil Court
State Income Tax
Citation
Case Number: 
2026 IL App (4th) 250121
Decision Date: 
Wednesday, February 25, 2026
District: 
4th Dist.
Division/County: 
Sangamon Co.
Holding: 
Affirmed.
Justice: 
ZENOFF

In a tax dispute, the plaintiffs appealed from a judgment in favor of the defendants. On appeal, plaintiffs argued that the trial court erred when it allowed a witness to offer opinions as an expert on the ultimate legal issues in the case, that the trial court erroneously concluded that a subsidiary of the plaintiffs did not qualify as an 80/20 company, and that the circumstances justified abating late-payment penalties. The appellate court affirmed, finding that the trial court did not err and that its determinations were not against the manifest weight of the evidence. (LANNERD and DeARMOND, concurring)