OPINION
JUSTICE COGHLAN delivered the judgment of the court, with opinion.
¶ 1 Petitioner Kishwaukee Auto Corral, Inc. (Kishwaukee), filed claims with the Illinois Department of Revenue (Department) for refunds of sales tax that it paid under the Retailers' Occupation Tax Act (ROTA) (35 ILCS 120/1 et seq. (West 2018)) on vehicles...
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