OPINION
Presiding Justice JORGENSEN delivered the judgment of the court, with opinion.
¶ 1 Plaintiff, Lisa Madigan, the Attorney General of the State of Illinois, on behalf of the People of the State of Illinois, filed a complaint under the Illinois Estate and Generation-Skipping Transfer Tax Act (Act) (35 ILCS 405/1 to 18 (West 2002)) against defendant, Julius Kole, personally. Plaintiff sought over $300,000 in additional estate tax, interest, and...
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