Articles From Jennifer Zimmerman

Formal notice of deficiency not required to commence protest monies action By Fred Marcus & Jennifer Zimmerman State and Local Taxation, September 2006 In National City Corporation v. Department of Revenue, 1-04-2907 (Ill. App. Ct., May 22, 2006),the Illinois Appellate Court, First District, has held that the “ripeness” doctrine does not preclude a taxpayer from filing a protest monies action after it received a notice of proposed deficiency for income taxes from the Illinois Department of Revenue (“Department”), but before it received a notice of deficiency that would trigger its right to administrative protest and review.

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