Justice STEIGMANN delivered the opinion of the court:
In July 1989, the Illinois Department of Revenue (Department) issued notices of penalty liability (NPLs) to plaintiff, Carl E. Branson, and his wife, Bonnie Branson, as responsible parties pursuant to section 13½ of the Retailers' Occupation Tax Act (Act) (Ill. Rev.Stat.1991, ch. 120, par. 452½). The penalties assessed related to unpaid taxes, interest, and penalties owed by Carbon, Inc. (Carbon), which...
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