Justice BOWMAN delivered the opinion of the court:
Plaintiff, Lombard Public Facilities Corporation (LPFC), appeals the decision of defendant, the Department of Revenue (Department), denying its application for exemption from the Retailers' Occupation Tax Act (Retailers' Tax Act) (35 ILCS 120/1 et seq. (West 2004)), pursuant to the exemption provided in section 2-5(11) of the Retailers' Tax Act.
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