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IN RE ENVIRODYNE INDUSTRIES, INC.

No. 02-1632.

354 F.3d 646 (2004)

In re: ENVIRODYNE INDUSTRIES, INC., et al., Debtors-Appellees. Appeal of: Illinois Department of Revenue.

United States Court of Appeals, Seventh Circuit.

Decided January 6, 2004.

Rehearing Denied January 26, 2004.

Attorney(s) appearing for the Case

Brian F. Barov (argued), Office of the Attorney General, Chicago, IL, for Appellant.

Jeffrey M. Schwartz, Gardner, Carton & Douglas, Chicago, IL, Alan Brilliant (argued), Milbank, Tweed, Hadley & McCloy, New York, NY, for Debtors-Appellees.

Before POSNER, EASTERBROOK, and EVANS, Circuit Judges.

POSNER, Circuit Judge.

The Illinois income tax statute requires firms that constitute a "unitary business group" to file a consolidated (called a "combined") return. 35 ILCS 5/502(e); Ill. Admin. Code tit. 86, § 100.5200. The quoted term signifies "a group of persons related through common ownership whose business activities are integrated with, dependent upon and contribute to each other." 35 ILCS 5/1501(a)(27). They must be "functionally integrated through...

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