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  5. 858 N.E.2d 909 (2006)
 

BD. OF REVIEW v. PROPERTY TAX APPEAL BD.

No. 5-04-0731.

858 N.E.2d 909 (2006)

306 Ill.Dec. 851

The CHRISTIAN COUNTY BOARD OF REVIEW, Plaintiff-Appellant, v. The PROPERTY TAX APPEAL BOARD, Carol Presnell, and Jack Presnell, Defendants-Appellees. The Christian County Board of Review, Plaintiff-Appellant, v. The Property Tax Appeal Board and Allen C. Braune, Defendants-Appellees. The Christian County Board of Review, Plaintiff-Appellant, v. The Property Tax Appeal Board and Robert A. Noreuil, Defendants-Appellees. The Christian County Board of Review, Plaintiff-Appellant, v. The Property Tax Appeal Board, Defendant-Appellee and Cross-Appellant, and Belinda Sexson, Defendant-Appellee.

Appellate Court of Illinois, Fifth District.

Motion to Publish Granted October 30, 2006.

Opinion Filed October 30, 2006.

Attorney(s) appearing for the Case

Brad Paisley, State's Attorney, Taylorville; Norbert J. Goetten, Director, Stephen E. Norris, Deputy Director, T. David Purcell, Staff Attorney, Office of the State's Attorneys Appellate Prosecutor, Mt. Vernon, for Appellant.

Brett E. Legner, Assistant Attorney General, Chicago, for The property Tax Appeal Board.

Jack Presnell, Pana, for Carol and Jack Presnell.

Justice WELCH delivered the opinion of the court:

In 1999, the Christian County Board of Review (County) assessed five manufactured homes located in Christian County as real property. Each owner of the manufactured homes separately appealed the assessments to the Property Tax Appeal Board (PTAB) and argued that the manufactured homes should be assessed as personalty and not real property. The PTAB agreed with each owner of the manufactured homes and found that because...

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