Justice McNULTY delivered the opinion of the court:
In 1995 Big Ten Conference, Inc. (the Big Ten), applied for a property tax exemption for a building in Park Ridge, Illinois. The Department of Revenue (Department) denied the application. The Big Ten requested a hearing before the Department's Office of Administrative Hearings. The administrative law judge (ALJ) recommended denial of the application, and the Director of the Department adopted the recommendation....
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