Justice MILLER delivered the opinion of the court:
The plaintiff, The Mutual Life Insurance Company of New York, brought the present declaratory judgment action in the circuit court of Sangamon County pursuant to the State Officers and Employees Money Disposition Act (Ill.Rev.Stat.1987, ch. 127, par. 170 et seq.). The plaintiff contests the assessment by the Illinois Department of Insurance (the Department) of a retaliatory tax (see Ill.Rev.Stat.1987, ch. 73...
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