OPINION
Presiding Justice HOFFMAN delivered the judgment of the court, with opinion.
¶ 1 The defendants, the Illinois Department of Revenue (Department), the Department's Director Brian Hamer, and Illinois State Treasurer Judith Baar Topinka, appeal the decision of the circuit court granting summary judgment to the plaintiffs, Tyler and Talbot Cain, on their complaint for a declaration that they are not required to pay resident Illinois income taxes...
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