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HORMEL FOODS CORP. v. ZEHNDER

No. 1-99-1319.

738 N.E.2d 145 (2000)

316 Ill.App.3d 1200

250 Ill.Dec. 181

HORMEL FOODS CORPORATION and Jennie-O-Foods, Inc., Plaintiffs-Appellants, v. Kenneth E. ZEHNDER, Director of the Department of Revenue, and The Department of Revenue, Defendants-Appellees.

Appellate Court of Illinois, First District, Sixth Division.

September 29, 2000.

Attorney(s) appearing for the Case

James E. Ryan, Joel D. Bertocchi, Edmund C. Baird, Chicago, for Appellees.

H. Randolph Williams, Michael S. Lee, Williams & Lee, LLC, Chicago, for Appellants.

Justice BUCKLEY delivered the opinion of the court:

Plaintiffs Hormel Foods Corporation and one of its subsidiaries, Jennie-O Foods, Inc. (collectively Taxpayers), appeal an order of the circuit court affirming a decision of the Director of the Illinois Department of Revenue (Director). The Director found that, for purposes of the Illinois Income Tax Act (Tax Act) (Ill.Rev. Stat.1981, ch. 120, par. 1-101 et seq. (now 35 ILCS 5/101 et seq. (West 1998...

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