Presiding Justice COUSINS delivered the opinion of the court:
Wayne and Alan Young were president and vice-president, respectively, as well as the owners, of Power Lift, Inc. (Power Lift). The Illinois Department of Revenue (the Department) assessed a penalty against Wayne, Alan and another officer of Power Lift for wilfully failing to pay the corporation's obligations under the Retailers' Occupation Tax Act (ROT Act) (35 ILCS 120/1 et seq. (West 1996)). They...
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