Justice McBRIDE delivered the opinion of the court:
This appeal arises from an administrative review action filed by plaintiff-appellee, Hollinger International, Inc. (Hollinger), against the defendant-appellant, the Illinois Department of Revenue (Department). The Department assessed certain penalties against Hollinger under section 1005(a) of the Illinois Income Tax Act (35 ILCS 5/1005(a)(West 2000))(Income Tax Act) due to Hollinger's underpayment of estimated income...
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