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  5. 106 Ill.2d 19 (1985)
 

DEP'T OF REV. v. HEARTLAND INVESTMENTS, INC.

Nos. 60289, 60298.

106 Ill.2d 19 (1985)

476 N.E.2d 413

THE DEPARTMENT OF REVENUE, Appellee, v. HEARTLAND INVESTMENTS, INC., et al. (Peter S. Vermeil, Appellant). — THE DEPARTMENT OF REVENUE, Appellant, v. HARTIGAN'S FINER FOODS, INC., et al., Appellees.

Supreme Court of Illinois.

Opinion filed March 22, 1985.

Attorney(s) appearing for the Case

David B. Radley, of Baymiller, Christison & Radley, of Peoria, for appellant.

Neil F. Hartigan, Attorney General, of Springfield (Jill Wine-Banks, Solicitor General, and Edward M. Kay, Assistant Attorney General, of Chicago, of counsel), for appellee.

Neil F. Hartigan, Attorney General, of Springfield (Edward M. Kay, Assistant Attorney General, of Chicago, of counsel), for appellant.

Raymond P. Carrol, of Chicago, for appellees.

Judgment affirmed. Appellate court affirmed in part and reversed in part; circuit court affirmed in part and reversed in part.

JUSTICE MORAN delivered the opinion of the court:

Plaintiff, the Department of Revenue of the State of Illinois (Department), instituted each of the actions involved in this consolidated appeal, by filing a complaint for the collection of unpaid retailers' occupation taxes (Ill. Rev. Stat. 1979, ch. 120, par. 440 et seq.) In...

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