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METROPOLITAN LIFE INS. CO. v. HAMER

No. 114234.

990 N.E.2d 1144 (2013)

2013 IL 114234

371 Ill. Dec. 766

METROPOLITAN LIFE INSURANCE COMPANY et al., Appellees, v. Brian HAMER, Director of the Illinois Department of Revenue, et al., Appellants.

Supreme Court of Illinois.

June 20, 2013.

Attorney(s) appearing for the Case

Lisa Madigan , Attorney General, Springfield ( Michael A. Scodro , Solicitor General, Eric Truett , Sunil S. Bhave , Assistant Attorneys General, Chicago, of counsel), for appellants.

John A. Biek , Andrea R. Dudding , Christopher D. Mickus , Neal, Gerber & Eisenberg, LLP, Chicago, for appellees.

Marilyn A. Wethekam , Fred O. Marcus , Horwood Marcus & Berk Chrtd., Chicago, for amicus curiae Counci on State Taxation.

OPINION

Justice GARMAN delivered the judgment of the court, with opinion.

¶ 1 In 2003, the Illinois General Assembly enacted the Tax Delinquency Amnesty Act (2003 Amnesty Act) (35 ILCS 745/10 (West 2004)), which established an amnesty program for all taxpayers owing any tax imposed by Illinois law. It further provided that, upon payment by a taxpayer of "all taxes due" for any taxable period between June 30, 1983, and July 1, 2002, the Department

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