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  5. 851 N.E.2d 79 (2006)
 

HONEYWELL INTERN., INC. v. DEPT. OF REVENUE

No. 1-03-2142.

851 N.E.2d 79 (2006)

HONEYWELL INTERNATIONAL, INC., formerly known as AlliedSignal, Inc., Plaintiff-Appellant, v. The DEPARTMENT OF REVENUE OF the STATE OF ILLINOIS, Defendant-Appellee.

Appellate Court of Illinois, First District, Fifth Division.

May 5, 2006.

Attorney(s) appearing for the Case

McDermott, Will & Emery, Chicago (Richard A. Hanson and Theodore R. Bots, of counsel), for Appellant.

Lisa Madigan, Attorney General, and Gary Feinerman, Solicitor General, Chicago (Diane M. Potts, of counsel), for Appellee.

Justice FROSSARD delivered the opinion of the court:

Plaintiff Honeywell International, Inc. (formerly known as AlliedSignal, Inc.), filed a complaint for administrative review against defendant the Illinois Department of Revenue (Department) after the Department assessed service occupation tax against it for tax years 1992, 1993, and 1994. Section 3 of the Service Occupation Tax Act (Act) imposes a service occupation tax on tangible personal property transferred...

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