Presiding Justice COUSINS delivered the opinion of the court:
On August 25, 1992, the trial court entered a decision and judgment order affirming the decision of an administrative law judge (ALJ) who determined that: (1) plaintiff, Soho Club, Inc., was subject to the Illinois Retailer's Occupation Tax Act (ROT Act) (35 ILCS 120/1 et seq. (West 1992)) for the tax years 1986 and 1987; and (2) plaintiff had not successfully rebutted defendant's, Illinois Department...
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