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ZUNAMON v. ZEHNDER

No. 1-98-1459.

719 N.E.2d 130 (1999)

308 Ill. App.3d 69

241 Ill.Dec. 269

Simon ZUNAMON, as Trustee of Oregon Trusts Nos. 1-208 and Washington Trusts Nos. 1-16, Marshall E. Eisenberg, as Trustee of A.N.P. Trusts Nos. 1-42 and R.A. Trusts Nos. 1-25, and Charles Evans Gerber, as Trustee of F.L.P. Trusts Nos. 10-17 and 19-21, Plaintiffs-Appellants, v. Kenneth E. ZEHNDER, Director of the Illinois Department of Revenue, and the Illinois Department Of Revenue, Defendants-Appellees.

Appellate Court of Illinois, First District, Fourth Division.

September 16, 1999.

Attorney(s) appearing for the Case

Michael D. Sher and Diane M. Anderson, Neal, Gerber & Eisenberg, Chicago, for Appellant.

James E. Ryan, Attorney General, Brian F. Barov, Assistant Attorney General, Chicago, for Appellees.

Justice HOURIHANE delivered the opinion of the court:

Plaintiffs, the trustees of certain taxpayer trusts, appeal an order of the circuit court affirming a decision of the Illinois Department of Revenue (Department), which determined that the trusts are not entitled to a foreign tax credit under section 601(b)(3) of the Illinois Income Tax Act (Act) (Ill.Rev.Stat.1987, ch. 120, par. 1-101 et seq.) against their Illinois income tax liability for tax years prior...

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