Justice HALL delivered the opinion of the court:
This case involves a tax protest action in which the plaintiff, E & E Hauling, Inc. (E & E), challenges the Illinois Secretary of State's (Secretary) assessment of approximately $512,000 in franchise taxes, license fees, and penalties. Such taxes and fees are calculated on the basis of a corporation's paid-in capital. Following a stock sale transaction between E & E's former sole shareholder and its acquiring...
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