Commercial Banking, Collections, and Bankruptcy

Avoiding Taxes on Phantom Income

By John W. Ryan
July
2025
Article
, Page 26
Can LLCs in Subchapter V bankruptcy reimburse their members for taxes owed on the “phantom income” they are no longer receiving?

Reimagining Lawyer Wellness: How Self-Care Sustains Us

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Master Series presented by the Illinois State Bar Association


1.0 hour MCLE credit, including 1.0 hour Professional Responsibility MCLE credit in the following category: Mental Health & Substance Abuse credit


Original Program Date: Monday, May 12, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­June 16, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Being a lawyer is one of the most stressful professions in the United States. Lawyers often have limited time for their own self-care, which greatly impacts their physical health, mental well-being, and work performance. This often leads to lawyers developing mental health concerns, chronic diseases, and burnout. Join us for an in-depth look at the strategies you can use to integrate self-care practices into your busy lives by creating daily routines that support your unique self-care needs. Learn how to set flexible boundaries that improve work life balance and develop avenues to integrate positive lifestyle habits into your demanding schedules in the areas of exercise, nutrition, mindfulness, sleep hygiene, and stress management.

Program Speaker:
Erin Clifford, Clifford Law Offices, Chicago
About the Speaker:
In addition to her development work at Clifford Law Offices and legal background, Erin Clifford is a Corporate Wellness Consultant and is a Licensed Professional Counselor in Illinois and a National Certified Counselor. She works with professionals to help them create and maintain healthy lifestyles. She has a master’s degree in mental health counseling from Northwestern University. As an authority figure in the wellness industry, Erin gives speaking engagements in all areas of wellness – from nutrition, to exercise, to healthy lifestyle management. Her expertise in wellness has earned her media attention from publications such as Shape Magazine, US News and World Report, Prevention Magazine, and more.

Program Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Nuts & Bolts of Subchapter V Chapter 11s

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Commercial, Banking, and Bankruptcy Law Section


2.0 hours MCLE credit


Original Program Date: Thursday, May 8, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­June 9, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Don’t miss this informative seminar that discusses the basic administration issues in subchapter V cases versus non-subchapter V cases, and helps you decide when subchapter V Chapter 11 is right for your clients. Business advice and financial planning attorneys, commercial banking lawyers, bankruptcy practitioners, and civil practice attorneys with basic to intermediate practice experience who attend this program will also learn:
  • The deadlines you need to be aware of;
  • How to represent a creditor in subchapter V; and
  • The pitfalls to avoid when handling these type of cases.

Program Coordinator:
Samuel H. Levine, Downey & Lenkov LLC, Chicago

Program Chat Moderator:
Julia Jensen Smolka, Robbins DiMonte, Ltd., Park Ridge

Program Speakers:
Laxmi P. Sarathy, Jurisprudence Health Law Group P.C., Naperville
Joan Ellen Smuda, Chief, Revenue Litigation Bureau, Office of the Illinois Attorney General, Chicago

Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $70 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $140
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

All About Real Estate Transactions: New 8.0 Contract, Post-Closing Agreements, Surveys, and Associations

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Real Estates Law Section


3.0 hours MCLE credit


Original Program Date: Tuesday, April 29, 2025
Accreditation Expiration Date: June 9, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Enhance your understanding of several key issues in residential real estate law, including the newly approved Multi-Board 8.0 Contract, with this half-day seminar! New attorneys, experienced attorneys, and non-real estate practitioners who attend this online program will be better prepared to handle all aspects of residential transactions, including:
  • The best practice tips you need to help protect your client during the post-closing agreement;
  • How to read surveys and the common issues that might arise on them; and
  • How HOA’s work, the documents you need to be familiar with, and the red flags to avoid.


Program Coordinator/Moderator:
Cheryl A. Morrison, Law Office of Cheryl A. Morrison, Mokena

Welcome & Introduction
Cheryl A Morrison, Law Office of Cheryl A. Morrison, Mokena

Post-Closing Possession Agreements
Post-closing possession agreements have become more common in recent years. This segment discusses best practices to protect both your buyer and seller clients.
Erica Crohn Minchella, Minchella & Associates, Ltd., Skokie

New Multi-Board 8.0 Contract
Get the information you need on both the substantive and organizational changes to the new Multi-Board 8.0 Contract that went into effect on February 1, 2025.
Ralph J. Schumann, Law Offices of Ralph J. Schumann, Schaumburg

Surveys
Surveys are an important but easily overlooked subject. Learn how to read surveys, what issues might arise, and how to resolve them with this informative presentation.
William J. Anaya, UB Greensfelder LLP, Chicago

Associations
Are you looking to understand homeowners’ associations and association documents better? Join us for a discussion regarding 22.1/1-35 Disclosures, paid assessment letters, and other required association documents, as well as red flags that can affect your clients.
Ellis Levin, Attorney at Law, Chicago


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $105 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $210
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

2025 Professionalism Bundle

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the Illinois State Bar Association


6.0 hours MCLE credit, including 6.0 hours Professional Responsibility MCLE credit in the following categories:
  • 4.0 hours Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit
  • 1.0 hour Diversity and Inclusion credit
  • 1.0 hour Mental Health and Substance Abuse credit
This bundle satisfies the 6 hour Professional Responsibility Requirement for a two-year reporting period under Supreme Court Rule 794(d).
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­May 28, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Satisfy all six hours of your Professional Responsibility requirement with this on-demand program that explores:
  • How to manage a positive work-life balance and practice mindful stress management;
  • How to work with witnesses, jurors, and experts who may differ from ourselves;
  • How artificial intelligence is being used in the legal practice, as well as the ethical issues to be aware of when using this technology;
  • How to identify problems that artificial intelligence can solve;
  • The best practice tips you need to build and maintain successful client management;
  • What you need to know about professional liability and cyber insurance; and
  • Much more!


Mental Health 101: Strategies for Thriving, Not Just Surviving
Originally presented by the ISBA Young Lawyers Division
(1.0 hour Mental Health or Substance Abuse MCLE/PMCLE credit)
As attorneys, we work long hours, juggle multiple cases simultaneously, spend a large amount of time researching case law and preparing legal documents, and have strict deadlines that must be remembered (and met!) – all while staying up to date on the ever-changing laws and regulations that will impact our clients and practice. These mental demands can take its toll and leave us feeling deflated, burnt out, and running on fumes. Join us for this online seminar that teaches you how to create a better work-life balance, while still meeting your professional and personal goals. Topics include: positive strategies to enhance your self-care; how to practice mindful stress management; tactics for building your resilience and mental fitness; and how to find your perfect mental health space.
Program Moderator: Courtney A. Berlin, Clifford Law Offices, Chicago
Erin Clifford, Clifford Law Offices, Chicago


Pronouns on Trial
Originally presented by the ISBA Standing Committee on Sexual Orientation and Gender Identity
(1.0 hours Diversity and Inclusion MCLE/PMCLE credit)
Transgender and non-binary individuals need the same respect and attentive representation as our other clients, but discomfort and implicit bias oftentimes get in our way. Join us online for this comprehensive discussion on how to work with witnesses, jurors, and experts who may differ from ourselves. Topics include: strategies for discovering honorifics and pronouns; how to address objections (both principled and vituperative); possible form changes (appearance/jury questionnaire); and the proposed changes to Illinois Rules of Professional Conduct 8.4 (Misconduct).
Program Coordinator/Moderator: John W. Moore, John W. Moore, P.C., Chicago
Hon. Mary Cay Marubio, Circuit Court of Cook County, Chicago
John W. Moore, John W. Moore, P.C., Chicago
Joanie Rae Wimmer, Law Offices of Joanie Rae Wimmer, Oak Park


The Dawning of the Age of Artificial Intelligence: Promise or Threat to the Practice of Law?
Originally presented by the ISBA Standing Committee on Artificial Intelligence & The Practice of Law
  • Artificial Intelligence and the Law: Promise or Peril?
(1.0 hour Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit)
Don’t miss this in-depth look at how artificial intelligence is being used in the legal practice, as well as the ethical issues to be aware of when using this technology. Topics include: recent developments in AI, type of AI, the application of artificial intelligence in the practice of law; how artificial intelligence is being used in the courts; and how to recognize (and address) Deep Fakes.
Program Moderator: George (“Geo”) Bellas, Bellas & Wachowski, Park Ridge
Jonathan Nessler, Nessler & Associates Ltd., Springfield
Nelson Rosario, Rosario Tech Law, LLC, Chicago
  • Practical Demonstration of Artificial Intelligence in the Practice
(1.0 hour Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit)
Learn how to identify problems that artificial intelligence can solve (and which AI tools to use in solving that problem) with this informative presentation. Examples of how artificial intelligence can assist with office tasks and market your law practice are also included.
Drew G. Vaughn, Deviant Marketing LLC, Chicago


Best Practices for Successful Client Management
Originally presented as part of the ISBA’s Solo & Small Firm Conference 2024
(1.0 hour Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit)
This segment offers the best practice tips you need to build and maintain successful client management. Topics include: intake, termination, and communication.
Program Moderator: Genevieve E. Miller, Singewald Law Firm, Chicago
Melissa Smart, Attorney Registration & Disciplinary Commission, Chicago


Safeguarding Your Practice: Navigating Insurance Coverage for Law Firms and Attorneys
Originally presented by the ISBA Standing Committee on Law Office Management and Economics
(1.0 hour Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit)
Join us for an in-depth look at how the right insurance coverage can safeguard you and your law practice, as well as the underwriting basics you need to know and the misconceptions regarding losses vs types of coverage. Solo and small firm attorneys, general practitioners, new lawyers, and insurance law attorneys with basic to intermediate practice experience who attend this seminar will better understand: What you need to know about professional liability and cyber insurance; the various types of insurance available to your practice; the importance of transparency in applying for coverage; the most common required underwriting information; business interruption coverage; commercial general liability and other coverage commonly required by landlords; key-person coverage and individual disability income coverage; and business overhead expenses.
Program Coordinator/Moderator: Jennifer Danish, Bryant Legal Group P.C. Chicago
Daniel Cotter, Dickinson Wright, Chicago
Adam Czerwinski, Sidebar Insurance Solutions, Orland Park
Jennifer Danish, Bryant Legal Group P.C. Chicago
Scott Dutton, ISBA Mutual Insurance Company, Chicago



Pricing Information
  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar. Your certificate will be available after all segments have been completed and the Bundle evaluation completed.
  • Fees:
    • ISBA Member Price of $159 is displayed below when you login and program is eligible for Free CLE member benefit
    • Non-Member Price $375
    • New Attorney Member (within the first five years of practice) - $50
    • Law Students - Free

Wilmington Trust v. Thor Palmer House Retail, LLC

Wilmington Trust v. Thor Palmer House Retail, LLC
Illinois Appellate Court
Civil Court
Mortgage Foreclosure
Citation
Case Number: 
2025 IL App (1st) 241085
Decision Date: 
Thursday, February 20, 2025
District: 
1st Dist.
Division/County: 
4th Div./Cook Co.
Holding: 
Affirmed in part, reversed in part, vacated in part, remanded.
Justice: 
HOFFMAN

In a commercial foreclosure action, the borrower appealed from a judgment entered in favor of the lender, arguing that the trial court erred by denying its motion for partial summary judgment, by including a paragraph in the final judgment that the borrower maintained amounted to an advisory opinion, and by granting the portion of the lender’s motion for summary judgment that awarded the lender a “prepayment premium.” The appellate court agreed with the borrower on the first two issues and as to the amount awarded in the third issued and affirmed in part, revered in part, vacated in part, and remanded with instructions. (ROCHFORD and LYLE, concurring)

Real Estate Law Update - Fall 2024 - Part 2

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Real Estate Law Section


3.25 hours MCLE credit, including 1.0 hour Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, and Sexual Harassment Prevention credit


Original Program Date: Thursday, November 7, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­February 25, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Get the updates you need on real estate law – from the legislative changes and recent case law that may impact your client or law practice, to the importance of having a succession plan in place in the event of your death, disability, or retirement. Lawyers with all levels of practice experience who attend this program, will better understand:
  • The basics of landlord and tenant law;
  • How to use the Partitions Act to help your client divide a parcel of land;
  • How to remove a mechanic’s lien from a title (and how to avoid them from attaching to a title in the first place);
  • What to do if your client’s post-closing agreement results in litigation;
  • And much more.

Program Coordinator/Moderator:
Laura L. Lundsgaard, Attorney & Counselor at Law, LLC, Inverness

Jungle Vines on Your Title: Mechanic’s Lien
This presentation shows you how to remove a mechanic’s lien from a title, while explaining what a mechanic’s lien is, how it takes priority, and how to avoid them from attaching to title.
Mark B. Grzymala, Grzymala Law Offices, Skokie
Samuel H. Levine, Downey and Lenkov LLC, Chicago

Partitions Act
Join us for an in-depth look at the Partitions Act, including what it is and how you can use this legislation to help your client when it’s time to split a parcel of land.
Gary R. Gehlbach, Ehrmann Gehlbach Badger & Considine, LLC, Dixon

Disagreements at the Closing Table: Post-Closing Agreements & Post-Closing Litigation
Learn how to represent your client in a post-closing agreement and how to handle if these agreements result in litigation.
Erica C. Minchella, Minchella & Associates, Ltd., Skokie

Succession Upon Death, Disability, or Retirement*
Colleagues, clients, and family are often left wondering how to deal with an attorney’s caseload upon the attorney’s death or disability. Do you have a succussion plan in place? This segment discusses the Illinois Rules of Professional Conduct that guide the succession of your client files and practice upon your death, disability, or retirement.
Anisa L. Jordan, Attorney Registration and Disciplinary Commission, Chicago

Program Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $113.75 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $227.50
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Real Estate Law Update - Fall 2024 - Part 1

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Real Estate Law Section


2.50 hours MCLE credit


Original Program Date: Thursday, November 7, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­February 24, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Get the updates you need on real estate law – from the legislative changes and recent case law that may impact your client or law practice, to the importance of having a succession plan in place in the event of your death, disability, or retirement. Lawyers with all levels of practice experience who attend this program, will better understand:
  • The basics of landlord and tenant law;
  • How to use the Partitions Act to help your client divide a parcel of land;
  • How to remove a mechanic’s lien from a title (and how to avoid them from attaching to a title in the first place);
  • What to do if your client’s post-closing agreement results in litigation;
  • And much more.

Program Coordinator/Moderator:
Laura L. Lundsgaard, Attorney & Counselor at Law, LLC, Inverness

Legislation Update
Don’t miss this comprehensive overview of the recent legislative developments that may impact your real estate clients or practice.
Bruno W. Tabis, Huck Bouma Attorneys at Law, Wheaton

Case Law Update
Keep abreast of the latest case law updates involving real estate matters with this informative presentation.
Joseph R. Fortunato, Mainstreet Organization of REALTORS®, Downers Grove

Perspectives from Landlords vs. Tenants
If you have never represented a landlord or tenant, then you won’t want to miss this segment as our speaker walks you through the basics of landlord and tenant law.
Hannah R. Lamore, Mahoney, Silverman, and Cross, LLC, Joliet


Program Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $87.50 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $175
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Collecting Judgments & Bankruptcy Issues Series: Collecting Against LLC Interests and Using Equitable Remedies to Enforce Judgments

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Commercial Banking, Collections, and Bankruptcy Section


1.50 hours MCLE credit


Original Program Date: Tuesday, February 4, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­February 10, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Don’t miss Part 3 of this three-part series as we discuss important issues to consider when collecting against LLC interests and using equitable remedies to enforce judgments. Topics include: strategies to enforce judgments against a judgment debtor’s ownership or interest in an LLC; the equitable remedy options available in judgment enforcements; actions for fraudulent conveyances; constructive trusts; piercing the corporate veil; and much more.


Program Coordinators:
Samuel H. Levine, Downey & Lenkov LLC, Chicago
Nathan Lollis, Law Offices of Nathan Lollis, LLC, Chicago

Program Chat Moderator:
 Samuel H. Levine, Downey & Lenkov LLC, Chicago

Program Speakers:
Keith Barnstein, Markoff Law LLC, Chicago
Laura E. Schrick, Mathis, Marifian & Ritcher, Ltd., Belleville


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $52.50 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $105
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Everything You Ever Wanted to Know about SALT (State and Local Taxation) but Were Afraid to Ask

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA State and Local Taxation Section


4.0 hours MCLE credit


Original Program Date: Wednesday, January 15, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­February 10, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Don’t miss this nuts-and-bolts discussion regarding the state and local taxation practice. Topics include: the current state of the tax law practice; a review of Illinois taxes; how to represent your client in a tax forum; an overview of the Illinois Department of Revenue; how to contest a property tax dispute before the Cook County Assessor’s Office or the Cook County Board of Review; and how virtual hearings can help the tax appeal process.


Program Coordinators/Moderators:
David Kupiec, Kupiec & Martin, LLC, Chicago
Gary H. Smith, Law Offices of Gary H. Smith, a division of KSN, Chicago

Understanding Today’s State and Local Tax Practice
Join us for an in-depth look at the impact that state income, sales and franchise tax have on the day-to-day operations of your clients’ businesses. Topics include: understanding what is required to do business in Illinois, such as registering with the State, remitting taxes, and filing tax returns; the importance of monitoring state tax legislation and changes to policy; income and sales tax nexus and sourcing; and how to plan for state tax audits and litigation.
David Kupiec, Kupiec & Martin, LLC, Chicago
Natalie Martin, Kupiec & Martin, LLC, Chicago

Local Taxes That Are Not Property Taxes
Gain a better understanding of amusement taxes, lease taxes, and more with this informative segment. A discussion on how to represent clients challenged with these unique issues is also included.
Samantha K. Breslow, Kilpatrick Townsend & Stockton LLP, Chicago

An Introduction to the Illinois Department of Revenue
This segment offers a comprehensive overview of the various procedures available for contesting a liability or claim denial, as well as a discussion on how to participate in the voluntary disclosure program, obtain relief through payment plans or offers in compromise, and more.
Brian Fliflet, Illinois Department of Revenue, Chicago

Property Tax Practice in Cook County
Don’t miss this presentation that gives you the information you need to represent clients who want to review and protest property tax on all types of properties. Topics include: how to represent your client when contesting a property tax assessment at the Cook County Assessor’s Office and the Cook County Board of Review; how to locate property tax assessment information; how to use the online filing system of the Cook County Assessor and Cook County Board of Review; and the circumstances and situation for seeking relief.
Lauren C. Elliott, Elliott & Associates, Chicago

Property Tax Practice Outside of Cook County
This session outlines and compares Illinois ad valorem assessments and appeals outside of Cook County, explores the rules, procedures, and local considerations regarding appeals in the collar counties and beyond, and discusses how the Property Tax Code is applied at a local level. A look at the various approaches for assessing and taxing real property outside of Cook County is also included.
Daniel Pappano, Zwelling Law, PLLC, Chicago

Virtual Hearings and the Tax Appeal Process
As traditional in-person tribunals struggle with accessibility and efficiency, digital platforms offer solutions to reduce travel barriers and geographic bias. This presentation explains how virtual hearings can transform legal services by addressing unmet needs and streamlining the tax appeal process, while offering best practice tips for implementation and compliance.
Mark D. Armstrong, Kane County Supervisor of Assessments, Geneva


Program Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $140 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $280
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free