OPINION
Presiding Justice QUINN delivered the judgment of the court, with opinion.
¶ 1 The Illinois Department of Revenue (Department) issued a notice of penalty tax liability (NPL) for the period of January 2006 through September 2006, against plaintiff, Jack P. Cerone, the majority shareholder of Grand-Wood Enterprises, Inc. (Grand-Wood), in connection with Grand-Wood's unpaid taxes, penalties, and interest under section 3-7(a) of the Uniform Penalty...
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