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92nd General Assembly

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Public Act 92-0826

SB2210 Enrolled                                LRB9212102SMdv

    AN ACT regarding taxes.

    Be it  enacted  by  the  People  of  the  State  of  Illinois,
represented in the General Assembly:

    Section 5.  The Department of Revenue Law  of  the  Civil
Administrative  Code  of  Illinois  is  amended  by  changing
Section 2505-275 as follows:

    (20 ILCS 2505/2505-275) (was 20 ILCS 2505/39e)
    Sec.   2505-275.   Tax   overpayments.  In  the  case  of
overpayment  of  any  tax  liability  arising  from  an   Act
administered by the Department, the Department may credit the
amount  of  the  overpayment and any interest thereon against
any final tax liability arising under that or any  other  Act
administered by the Department. The Department may enter into
agreements  with  the Secretary of the Treasury of the United
States (or his or her delegate) to offset all or part  of  an
overpayment  of  such  a  tax liability against any liability
arising from a tax imposed  under  Title  26  of  the  United
States  Code.  The  Department  may  collect  a  fee from the
Secretary of the Treasury of the United States (or his or her
delegate) to cover the full cost of  offsets  taken,  to  the
extent  allowed by federal law, or, if not allowed by federal
law, from the taxpayer by offset of the overpayment.
(Source: P.A. 91-239, eff. 1-1-00; 92-492, eff. 1-1-02.)

    Section 10.  The Illinois Income Tax Act  is  amended  by
changing  Sections  601,  911.2,  1102, 1103, and 1105 and by
adding Section 911.3 as follows:

    (35 ILCS 5/601) (from Ch. 120, par. 6-601)
    Sec. 601. Payment on Due Date of Return.
    (a)  In general. Every taxpayer required to file a return
under this Act shall, without assessment, notice  or  demand,
pay any tax due thereon to the Department, at the place fixed
for  filing,  on  or  before  the  date fixed for filing such
return (determined without regard to any  extension  of  time
for  filing the return) pursuant to regulations prescribed by
the Department. If, however, the due date for  payment  of  a
taxpayer's  federal  income  tax liability for a tax year (as
provided  in  the  Internal  Revenue  Code  or  by   Treasury
regulation,  or  as extended by the Internal Revenue Service)
is later than  the  date  fixed  for  filing  the  taxpayer's
Illinois  income tax return for that tax year, the Department
may, by rule, prescribe a due date for payment  that  is  not
later than the due date for payment of the taxpayer's federal
income   tax   liability.   For   purposes  of  the  Illinois
Administrative  Procedure  Act,  the  adoption  of  rules  to
prescribe a later due date for payment  shall  be  deemed  an
emergency  and necessary for the public interest, safety, and
welfare.
    (b)  Amount payable. In making  payment  as  provided  in
this  section  there shall remain payable only the balance of
such tax remaining due after giving effect to the following:
    (1)  Withheld  tax.  Any  amount  withheld   during   any
calendar year pursuant to Article 7 from compensation paid to
a  taxpayer  shall  be deemed to have been paid on account of
any tax imposed by subsections 201(a) and (b) of this Act  on
such taxpayer for his taxable year beginning in such calendar
year.  If  more  than  one  taxable year begins in a calendar
year, such amount shall  be  deemed  to  have  been  paid  on
account of such tax for the last taxable year so beginning.
    (2)  Estimated  and tentative tax payments. Any amount of
estimated tax paid by a taxpayer pursuant to Article 8 for  a
taxable  year shall be deemed to have been paid on account of
the tax imposed by this Act for such taxable year.
    (3)  Foreign tax. The aggregate amount of  tax  which  is
imposed  upon  or  measured  by income and which is paid by a
resident for a taxable year to another  state  or  states  on
income   which   is  also  subject  to  the  tax  imposed  by
subsections 201(a) and (b) of  this  Act  shall  be  credited
against  the  tax  imposed  by  subsections  201(a)  and  (b)
otherwise  due  under  this  Act  for  such taxable year. The
aggregate credit provided  under  this  paragraph  shall  not
exceed  that  amount  which  bears  the same ratio to the tax
imposed by subsections 201(a) and  (b)  otherwise  due  under
this  Act as the amount of the taxpayer's base income subject
to tax both by such other state or states and by  this  State
bears  to  his total base income subject to tax by this State
for the taxable year. For purposes  of  this  subsection,  no
compensation  received  by  a  resident  which  qualifies  as
compensation  paid  in this State as determined under Section
304(a)(2)(B) shall be considered income  subject  to  tax  by
another  state  or  states.   The  credit  provided  by  this
paragraph  shall  not  be  allowed  if any creditable tax was
deducted in determining base income for the taxable year. Any
person claiming such  credit  shall  attach  a  statement  in
support  thereof  and shall notify the Director of any refund
or reductions in the  amount  of  tax  claimed  as  a  credit
hereunder  all  in  such  manner  and  at  such  time  as the
Department shall by regulations prescribe.
    (4)  Accumulation and capital gain distributions. If  the
net  income  of  a  taxpayer includes amounts included in his
base income by reason of Section 668 or 669 of  the  Internal
Revenue  Code  (relating  to  accumulation  and  capital gain
distributions by a trust, respectively), the tax  imposed  on
such taxpayer by this Act shall be credited with his pro rata
portion  of  the  taxes imposed by this Act on such trust for
preceding taxable years which would not have been payable for
such  preceding  years  if  the  trust  had  in   fact   made
distributions  to  its  beneficiaries at the times and in the
amounts specified in Sections 666 and  669  of  the  Internal
Revenue Code. The credit provided by this paragraph shall not
reduce  the  tax otherwise due from the taxpayer to an amount
less than that which would be due if the amounts included  by
reason  of  Sections 668 and 669 of the Internal Revenue Code
were excluded from his base income.
    (c)  Cross reference. For application against tax due  of
overpayments of tax for a prior year, see Section 909.
(Source: P.A. 85-731.)

    (35 ILCS 5/911.2)
    Sec.  911.2.   Refunds  withheld;  tax  claims  of  other
states.
    (a)  Definitions.   In  this  Section the following terms
have the meanings indicated.
    "Claimant state" means  any  state  or  the  District  of
Columbia  that  requests the withholding of a refund pursuant
to this Section and  that  extends  a  like  comity  for  the
collection of taxes owed to this State.
    "Income  tax"  means  any amount of income tax imposed on
taxpayers under the laws of the  State  of  Illinois  or  the
claimant  state, including additions to tax for penalties and
interest.
    "Refund" means a refund of overpaid income taxes  imposed
by the State of Illinois or the claimant state.
    "Tax  officer"  means  a unit or official of the claimant
state, or the duly authorized agent of that unit or official,
charged with the imposition,  assessment,  or  collection  of
state income taxes.
    "Taxpayer"  means  any  individual person identified by a
claimant state under this Section  as  owing  taxes  to  that
claimant  state, and in the case of a refund arising from the
filing of a joint return, the taxpayer's spouse.
    (b)  In general.  Except as provided in subsection (c) of
this Section, a tax officer may:
         (1)  certify to the  Director  the  existence  of  a
    taxpayer's delinquent income tax liability; and
         (2)  request  the Director to withhold any refund to
    which the taxpayer is entitled.
    (c)  Comity.  A tax officer may not  certify  or  request
the  Director  to  withhold  a  refund unless the laws of the
claimant state:
         (1)  allow the Director to  certify  an  income  tax
    liability;
         (2)  allow  the  Director to request the tax officer
    to withhold the taxpayer's tax refund; and
         (3)  provide for the payment of the  refund  to  the
    State of Illinois.
    (d)  Certification.   A certification by a tax officer to
the Director shall include:
         (1)  the full name and address of the  taxpayer  and
    any other names known to be used by the taxpayer;
         (2)  the  social  security  number  or  federal  tax
    identification number of the taxpayer;
         (3)  the amount of the income tax liability; and
         (4)  a   statement   that   all  administrative  and
    judicial remedies and appeals have been exhausted or have
    lapsed and that the  assessment  of  tax,  interest,  and
    penalty has become final.
    (e)  Notification.   As to any taxpayer due a refund, the
Director shall:
         (1)  notify the taxpayer that a claimant  state  has
    provided  certification of the existence of an income tax
    liability;
         (2)  inform  the  taxpayer  of  the  tax   liability
    certified,   including  a  detailed  statement  for  each
    taxable year showing tax, interest, and penalty;
         (3)  inform the taxpayer  that  failure  to  file  a
    protest in accordance with subsection (f) of this Section
    shall  constitute  a  waiver  of  any demand against this
    State for the amount certified;
         (3.5)  inform the taxpayer that the refund has  been
    withheld  and that the tax liability has been paid to the
    claimant state as provided  in  subsection  (i)  of  this
    Section  and will result in payment to the claimant state
    as provided in subsection (i) of this Section;
         (4)  provide  the  taxpayer  with   notice   of   an
    opportunity   to  request  a  hearing  to  challenge  the
    certification; and
         (5)  inform the taxpayer that  the  hearing  may  be
    requested  (i)   pursuant  to Section 910 of this Act, or
    (ii) with the tax officer, in accordance with the laws of
    the claimant state.
    (f)  Protest of withholding.  A taxpayer may protest  the
withholding  of  a refund pursuant to Section 910 of this Act
(except that the protest shall be filed within 30 days  after
the  date  of the Director's notice of certification pursuant
to subsection (e) of this Section).  If a  taxpayer  files  a
timely protest, the Director shall:
         (1)  suspend  the  proposed  withholding and impound
    the claimed amount of the refund;
         (2)  pay to the taxpayer the unclaimed amount of the
    refund, if any;
         (3)  send a copy of  the  protest  to  the  claimant
    state  for  determination of the protest on its merits in
    accordance with the laws of that state; and
         (4)  pay over to the taxpayer the  impounded  amount
    if  the  claimant  state shall fail, within 45 days after
    the date of the protest, to re-certify  to  the  Director
    (i)  that  the  claimant  state  has  reviewed the issues
    raised by taxpayer,  (ii)  that  all  administrative  and
    judicial  remedies  provided under the laws of that state
    have been exhausted, and (iii) the amount of  the  income
    tax liability finally determined to be due.
    (g)  Certification  as  prima  facie  evidence.   If  the
taxpayer  requests  a hearing pursuant to Section 910 of this
Act, the certification of the  tax  officer  shall  be  prima
facie   evidence   of   the  correctness  of  the  taxpayer's
delinquent income tax liability to the certifying state.
    (h)  Rights of spouses to refunds from joint returns.  If
a certification is based  upon  the  tax  debt  of  only  one
taxpayer  and  if  the  refund is based upon a joint personal
income tax return, the nondebtor spouse shall have the  right
to:
         (1)  notification,  as provided in subsection (e) of
    this Section;
         (2)  protest, as to the withholding of such spouse's
    share of the refund, as provided  in  subsection  (f)  of
    this Section; and
         (3)  payment  of  his  or  her  share of the refund,
    provided the amount of the overpayment  refunded  to  the
    spouse   shall   not  exceed  the  amount  of  the  joint
    overpayment.
    (i)  Withholding and payment of refund.  Subject  to  the
taxpayer's  rights  of  notice and protest, Upon receipt of a
request for withholding in accordance with subsection (b)  of
this Section, the Director shall:
         (1)  withhold  any  refund  that is certified by the
    tax officer;
         (2)  pay to the claimant state the entire refund  or
    the amount certified, whichever is less;
         (3)  pay   any   refund  in  excess  of  the  amount
    certified to the taxpayer; and
         (4)  if a refund is less than the amount  certified,
    withhold   amounts   from   subsequent  refunds  due  the
    taxpayer, if the laws of the claimant state provide  that
    the  claimant  state shall withhold subsequent refunds of
    taxpayers certified to that state by the Director.
    (j)  Determination  that  withholding  cannot  be   made.
After  receiving  a  certification  from  a  tax officer, the
Director shall notify the  claimant  state  if  the  Director
determines that a withholding cannot be made.
    (k)  Director's  authority.   The Director shall have the
authority to enter into agreements with the tax  officers  of
claimant state relating to:
         (1)  procedures  and  methods  to  be  employed by a
    claimant state with respect  to  the  operation  of  this
    Section;
         (2)  safeguards    against    the    disclosure   or
    inappropriate  use  of  any   information   obtained   or
    maintained  pursuant  to  this  Section  that identifies,
    directly or indirectly, a particular taxpayer;
         (3)  a minimum tax debt,  amounts  below  which,  in
    light  of  administrative expenses and efficiency, shall,
    in the Director's  discretion,  not  be  subject  to  the
    withholding procedures set forth in this Section.
    (l)  Remedy  not  exclusive.   The  collection procedures
prescribed by this Section are in addition  to,  and  not  in
substitution for, any other remedy available by law.
(Source: P.A. 92-492, eff. 1-1-02.)

    (35 ILCS 5/911.3 new)
    Sec. 911.3. Refunds withheld; order of honoring requests.
The Department shall honor refund withholding requests in the
following order:
         (1)  a  refund  withholding  request  to  collect an
    unpaid State tax;
         (2)  a  refund  withholding   request   to   collect
    certified  past  due  child support amounts under Section
    2505-650 of the Department of Revenue Law  of  the  Civil
    Administrative Code of Illinois;
         (3)  a  refund  withholding  request  to collect any
    debt owed to the State;
         (4)  a  refund  withholding  request  made  by   the
    Secretary of the Treasury of the United States, or his or
    her  delegate,  to collect any tax liability arising from
    Title 26 of the United States Code; and
         (5)  a  refund  withholding  request   pursuant   to
    Section 911.2 of this Act.

    (35 ILCS 5/1102) (from Ch. 120, par. 11-1102)
    Sec. 1102. Jeopardy Assessments.
    (a)  Jeopardy assessment and lien.
         (1)  Assessment.  If  the  Department  finds  that a
    taxpayer is about to depart from the State, or to conceal
    himself or his property, or to do any other  act  tending
    to  prejudice  or  to render wholly or partly ineffectual
    proceedings to collect any amount  of  tax  or  penalties
    imposed  under  this  Act  unless  court  proceedings are
    brought without delay, or if the  Department  finds  that
    the  collection  of  such  amount  will be jeopardized by
    delay, the Department shall give the taxpayer  notice  of
    such  findings and shall make demand for immediate return
    and payment of such amount, whereupon such  amount  shall
    be  deemed  assessed and shall become immediately due and
    payable.
         (2)  Filing of lien. If the taxpayer, within 5  days
    after  such  notice  (or within such extension of time as
    the Department may grant),  does  not  comply  with  such
    notice  or  show  to  the Department that the findings in
    such notice are erroneous,  the  Department  may  file  a
    notice  of  jeopardy assessment lien in the office of the
    recorder of the county  in  which  any  property  of  the
    taxpayer  may be located and shall notify the taxpayer of
    such filing. Such jeopardy assessment lien shall have the
    same scope and effect as a statutory lien under this Act.
    The taxpayer is liable for the filing fee incurred by the
    Department  for  filing  the  lien  and  the  filing  fee
    incurred by the Department to file the  release  of  that
    lien.  The filing fees shall be paid to the Department in
    addition to payment of the  tax,  penalty,  and  interest
    included in the amount of the lien.
    (b)  Termination  of  taxable  year. In the case of a tax
for a current taxable year, the Director  shall  declare  the
taxable period of the taxpayer immediately terminated and his
notice  and  demand for a return and immediate payment of the
tax shall relate to the period declared terminated, including
therein income accrued and deductions incurred up to the date
of  termination  if  not  otherwise  properly  includible  or
deductible in respect of such taxable year.
    (c)  Protest. If the taxpayer believes that he  does  not
owe  some  or  all  of  the  amount  for  which  the jeopardy
assessment lien against  him  has  been  filed,  or  that  no
jeopardy to the revenue in fact exists, he may protest within
20  days after being notified by the Department of the filing
of such jeopardy  assessment  lien  and  request  a  hearing,
whereupon  the  Department shall hold a hearing in conformity
with the provisions of section  908  and,  pursuant  thereto,
shall  notify  the  taxpayer of its decision as to whether or
not such jeopardy assessment lien will be released.
(Source: P.A. 83-358.)

    (35 ILCS 5/1103) (from Ch. 120, par. 11-1103)
    Sec. 1103.  Filing and Priority of Liens. (a) Filing with
Recorder. Nothing in this Article shall be construed to  give
the  Department a preference over the rights of any bona fide
purchaser, holder of a security interest,  mechanics  lienor,
mortgagee,  or  judgment  lien  creditor arising prior to the
filing of a regular notice of lien or a  notice  of  jeopardy
assessment  lien  in the office of the recorder in the county
in which the property subject to the  lien  is  located.  For
purposes  of  this  section,  the term "bona fide," shall not
include any mortgage of real  or  personal  property  or  any
other credit transaction that results in the mortgagee or the
holder  of  the  security  acting  as  trustee  for unsecured
creditors of the taxpayer mentioned in the notice of lien who
executed such  chattel  or  real  property  mortgage  or  the
document  evidencing such credit transaction. Such lien shall
be inferior to the lien of general taxes, special assessments
and special taxes  heretofore  or  hereafter  levied  by  any
political subdivision of this State.
    (b)  Filing  with  Registrar. In case title to land to be
affected  by  the  notice  of  lien  or  notice  of  jeopardy
assessment lien is registered under the provisions of "An Act
concerning land titles," approved May 1,  1897,  as  amended,
such  notice shall be filed in the office of the Registrar of
Titles of the county within which the property subject to the
lien is situated and shall be entered upon  the  register  of
titles  as  a  memorial  of  charge  upon  each folium of the
register  of  titles  affected  by  such  notice,   and   the
Department shall not have a preference over the rights of any
bona  fide  purchaser,  mortgagee, judgment creditor or other
lien holder arising prior to the registration of such notice.
    (c)  Index. The recorder of each county shall  procure  a
file  labeled  "State  Tax  Lien  Notices"  and an index book
labeled "State Tax Lien Index." When notice of  any  lien  or
jeopardy  assessment  lien is presented to him for filing, he
shall file it in numerical order in the file and shall  enter
it alphabetically in the index. The entry shall show the name
and last known address of the person named in the notice, the
serial  number  of  the  notice, the date and hour of filing,
whether it is a regular lien or a jeopardy  assessment  lien,
and  the  amount  of tax and penalty due and unpaid, plus the
amount of interest due at the time when the notice of lien or
jeopardy assessment is filed.
    (d)  No recorder or registrar of  titles  of  any  county
shall  require  that  the Department pay any costs or fees in
connection with recordation of any notice or  other  document
filed  by  the  Department  under  this  Act at the time such
notice or other document is presented  for  recordation.  The
recorder  or  registrar  of  each county, in order to receive
payment for fees or costs incurred by the  Department,  shall
present the Department with monthly statements indicating the
amount  of  fees and costs incurred by the Department and for
which no payment has been received. This  amendatory  Act  of
1987 applies to all liens heretofore or hereafter filed.
    (e)  The  taxpayer  is liable for the filing fee incurred
by the Department for filing the  lien  and  the  filing  fee
incurred  by the Department to file the release of that lien.
The filing fees shall be paid to the Department  in  addition
to  payment of the tax, penalty, and interest included in the
amount of the lien.
(Source: P.A. 86-905.)

    (35 ILCS 5/1105) (from Ch. 120, par. 11-1105)
    Sec. 1105. Release of Liens.
    (a)  In general. Upon payment  by  the  taxpayer  to  the
Department  in  cash or by guaranteed remittance of an amount
representing the filing fees and charges for the lien and the
filing fees and charges for the release  of  that  lien,  the
Department  shall  release all or any portion of the property
subject to any lien provided for in this Act  and  file  that
complete  or partial release of lien with the recorder of the
county where that lien was filed if it  determines  that  the
release will not endanger or jeopardize the collection of the
amount secured thereby.
    (b)  Judicial  determination.  If  on judicial review the
final judgment of the court is that the taxpayer does not owe
some or all of the amount secured by the lien against him, or
that no jeopardy to the revenue exists, the Department  shall
release   its   lien   to  the  extent  of  such  finding  of
nonliability, or to the extent of such finding of no jeopardy
to the revenue. The taxpayer shall, however,  be  liable  for
the  filing  fee  paid by the Department to file the lien and
the filing fee required to file a release of  the  lien.  The
filing fees shall be paid to the Department.
    (c)  Payment.  The  Department  shall  also  release  its
jeopardy  assessment  lien  against the taxpayer whenever the
tax and penalty covered by such lien, plus any interest which
may be due and an amount representing the filing fee to  file
the  lien  and  the  filing fee required to file a release of
that lien, are paid by the taxpayer to the Department in cash
or by guaranteed remittance.
    (d)  Certificate of release. The Department shall issue a
certificate of complete or partial release of the  lien  upon
payment  by  the  taxpayer  to  the  Department in cash or by
guaranteed remittance of an amount  representing  the  filing
fee  paid  by  the Department to file the lien and the filing
fee required to file the release of that lien:
    (1)  To the extent that the  fair  market  value  of  any
property  subject  to the lien exceeds the amount of the lien
plus the amount of all prior liens upon such property;
    (2)  To  the  extent  that   such   lien   shall   become
unenforceable;
    (3)  To  the  extent that the amount of such lien is paid
by the  person  whose  property  is  subject  to  such  lien,
together  with  any interest and penalty which may become due
under this Act between the date when the notice  of  lien  is
filed and the date when the amount of such lien is paid;
    (4)  To  the  extent  that  there  is  furnished  to  the
Department  on  a  form  to  be approved and with a surety or
sureties satisfactory  to  the  Department  a  bond  that  is
conditioned  upon  the  payment  of  the amount of such lien,
together with any interest which may become  due  under  this
Act  after the notice of lien is filed, but before the amount
thereof is fully paid;
    (5)  To the extent and under the circumstances  specified
in this section. A certificate of complete or partial release
of  any  lien shall be held conclusive that the lien upon the
property covered by the certificate is  extinguished  to  the
extent indicated by such certificate.
    Such  release  of  lien shall be issued to the person, or
his agent, against whom  the  lien  was  obtained  and  shall
contain in legible letters a statement as follows:
    FOR THE PROTECTION OF THE OWNER, THIS RELEASE SHALL
    BE FILED WITH THE RECORDER OR THE REGISTRAR
    OF TITLES, IN WHOSE OFFICE, THE LIEN WAS FILED.
    (e)  Filing.  When  a  certificate of complete or partial
release of lien issued by the  Department  is  presented  for
filing  in  the office of the recorder or Registrar of Titles
where a notice of lien or notice of jeopardy assessment  lien
was filed:
    (1)  The recorder, in the case of nonregistered property,
shall  permanently  attach  the certificate of release to the
notice of lien or notice  of  jeopardy  assessment  lien  and
shall  enter  the  certificate of release and the date in the
"State Tax Lien Index" on the line where the notice  of  lien
or notice of jeopardy assessment lien is entered; and
    (2)  In the case of registered property, the Registrar of
Titles  shall file and enter upon each folium of the register
of titles affected thereby a memorial of the  certificate  of
release which memorial when so entered shall act as a release
pro tanto of any memorial of such notice of lien or notice of
jeopardy assessment lien previously filed and registered.
(Source: P.A. 85-731.)

    Section 15.  The Retailers' Occupation Tax Act is amended
by changing Sections 5a, 5b, and 5c as follows:

    (35 ILCS 120/5a) (from Ch. 120, par. 444a)
    Sec.  5a.   The  Department shall have a lien for the tax
herein imposed or any portion thereof,  or  for  any  penalty
provided for in this Act, or for any amount of interest which
may be due as provided for in Section 5 of this Act, upon all
the  real and personal property of any person to whom a final
assessment or revised final assessment  has  been  issued  as
provided  in  this Act, or whenever a return is filed without
payment of the tax  or  penalty  shown  therein  to  be  due,
including  all  such  property of such persons acquired after
receipt of such assessment or  filing  of  such  return.  The
taxpayer  is  liable  for  the  filing  fee  incurred  by the
Department for filing the lien and the filing fee incurred by
the Department to file the release of that lien.  The  filing
fees  shall  be paid to the Department in addition to payment
of the tax, penalty, and interest included in the  amount  of
the lien.
    However, where the lien arises because of the issuance of
a  final  assessment  or  revised  final  assessment  by  the
Department,  such  lien  shall  not  attach  and  the  notice
hereinafter  referred  to  in this Section shall not be filed
until all proceedings in  court  for  review  of  such  final
assessment or revised final assessment have terminated or the
time   for  the  taking  thereof  has  expired  without  such
proceedings being instituted.
    Upon the granting of a rehearing or  departmental  review
pursuant  to  Section 4 or Section 5 of this Act after a lien
has attached, such lien shall remain in full force except  to
the  extent to which the final assessment may be reduced by a
revised final assessment following such rehearing or review.
    The lien created by the issuance of  a  final  assessment
shall terminate unless a notice of lien is filed, as provided
in  Section  5b  hereof,  within  3  years  from the date all
proceedings in court for the review of such final  assessment
have  terminated  or  the  time  for  the  taking thereof has
expired without such proceedings being instituted, or (in the
case of a revised  final  assessment  issued  pursuant  to  a
rehearing  or  departmental  review)  within 3 years from the
date all proceedings in court for the review of such  revised
final  assessment  have terminated or the time for the taking
thereof  has   expired   without   such   proceedings   being
instituted;  and  where the lien results from the filing of a
return without payment of the tax or penalty shown therein to
be due, the lien shall terminate unless a notice of  lien  is
filed,  as provided in Section 5b hereof, within 3 years from
the date when such  return  is  filed  with  the  Department:
Provided  that the time limitation period on the Department's
right to file a notice of  lien  shall  not  run  during  any
period of time in which the order of any court has the effect
of  enjoining  or restraining the Department from filing such
notice of lien.
    If the Department finds  that  a  taxpayer  is  about  to
depart from the State, or to conceal himself or his property,
or  to  do  any  other  act tending to prejudice or to render
wholly or partly ineffectual proceedings to collect such  tax
unless  such proceedings are brought without delay, or if the
Department finds that the collection of the amount  due  from
any  taxpayer  will  be  jeopardized by delay, the Department
shall give the taxpayer notice of  such  findings  and  shall
make  demand  for  immediate  return and payment of such tax,
whereupon such tax shall become immediately due and  payable.
If  the  taxpayer, within 5 days after such notice (or within
such extension of time as the Department may grant), does not
comply with such notice or show to the  Department  that  the
findings  in  such  notice  are erroneous, the Department may
file a notice of jeopardy assessment lien in  the  office  of
the  recorder  of  the  county  in  which any property of the
taxpayer may be located and shall notify the taxpayer of such
filing. Such jeopardy assessment lien  shall  have  the  same
scope  and effect as the statutory lien hereinbefore provided
for in this Section.
    If the taxpayer believes that he does not owe some or all
of the tax for which the jeopardy assessment lien against him
has been filed, or that no jeopardy to the  revenue  in  fact
exists, he may protest within 20 days after being notified by
the Department of the filing of such jeopardy assessment lien
and  request a hearing, whereupon the Department shall hold a
hearing in conformity with the provisions of  this  Act  and,
pursuant  thereto,  shall notify the taxpayer of its findings
as to whether or not such jeopardy assessment  lien  will  be
released.  If  not,  and if the taxpayer is aggrieved by this
decision, he  may file an action for judicial review of  such
final  determination  of  the  Department  in accordance with
Section 12 of this Act and the Administrative Review Law.
    If, pursuant to such hearing  (or  after  an  independent
determination  of  the  facts  by  the  Department  without a
hearing), the Department determines that some or all  of  the
tax  covered  by  the jeopardy assessment lien is not owed by
the taxpayer, or that no jeopardy to the revenue  exists,  or
if on judicial review the final judgment of the court is that
the  taxpayer  does not owe some or all of the tax covered by
the jeopardy assessment lien against him, or that no jeopardy
to the revenue  exists,  the  Department  shall  release  its
jeopardy  assessment  lien  to  the extent of such finding of
nonliability for the tax, or to the extent of such finding of
no jeopardy to the revenue.
    The Department shall also release its jeopardy assessment
lien against  the  taxpayer  whenever  the  tax  and  penalty
covered by such lien, plus any interest which may be due, are
paid  and  the taxpayer has paid the Department in cash or by
guaranteed remittance an amount representing the  filing  fee
for the lien and the filing fee for the release of that lien.
The  Department  shall  file  that  release  of lien with the
recorder of the county where that lien was filed.
    Nothing in this Section shall be construed  to  give  the
Department  a  preference  over  the  rights of any bona fide
purchaser,  holder  of   a   security   interest,   mechanics
lienholder,  mortgagee,  or  judgment  lien  creditor arising
prior to the filing of a regular notice of lien or  a  notice
of  jeopardy assessment lien in the office of the recorder in
the county in which the  property  subject  to  the  lien  is
located:  Provided,  however,  that  the word "bona fide", as
used in this Section shall not include any mortgage  of  real
or  personal  property  or  any other credit transaction that
results in the mortgagee or the holder of the security acting
as trustee for unsecured creditors of the taxpayer  mentioned
in  the  notice  of  lien  who  executed such chattel or real
property mortgage or  the  document  evidencing  such  credit
transaction.  Such  lien  shall  be  inferior  to the lien of
general  taxes,  special  assessments   and   special   taxes
heretofore  or  hereafter levied by any political subdivision
of this State.
    In case title to land to be affected  by  the  notice  of
lien  or  notice  of  jeopardy  assessment lien is registered
under the provisions of  "An  Act  concerning  land  titles",
approved  May 1, 1897, as amended, such notice shall be filed
in the office of the Registrar of Titles of the county within
which the property subject to the lien is situated and  shall
be  entered  upon  the  register  of  titles as a memorial or
charge upon each folium of the register of titles affected by
such notice, and the Department shall not have  a  preference
over  the  rights  of  any  bona  fide  purchaser, mortgagee,
judgment creditor or other lien holder arising prior  to  the
registration of such notice: Provided, however, that the word
"bona  fide"  shall  not  include  any  mortgage  of  real or
personal  property  or  any  other  credit  transaction  that
results in the mortgagee or the holder of the security acting
as trustee for unsecured creditors of the taxpayer  mentioned
in  the  notice  of  lien  who  executed such chattel or real
property mortgage or  the  document  evidencing  such  credit
transaction.
    Such  regular  lien or jeopardy assessment lien shall not
be effective against any purchaser with respect to  any  item
in a retailer's stock in trade purchased from the retailer in
the usual course of such retailer's business.
(Source: P.A. 86-905.)

    (35 ILCS 120/5b) (from Ch. 120, par. 444b)
    Sec.  5b.   The  recorder  of each county shall procure a
file labeled "State Tax  Lien  Notices"  and  an  index  book
labeled  "State  Tax  Lien Index". When notice of any lien or
jeopardy assessment lien is presented to him for  filing,  he
shall  file it in numerical order in the file and shall enter
it alphabetically in the index. The entry shall show the name
and last known business address of the person  named  in  the
notice, the serial number of the notice, the date and hour of
filing, whether it is a regular lien or a jeopardy assessment
lien,  and the amount of tax and penalty due and unpaid, plus
the amount of interest due under Section 5 of this Act at the
time when the notice of lien or jeopardy assessment  lien  is
filed.
    No  recorder  or  registrar of titles of any county shall
require  that  the  Department  pay  any  costs  or  fees  in
connection with recordation of any notice or  other  document
filed  by  the  Department  under  this  Act at the time such
notice or other document is presented  for  recordation.  The
recorder  or  registrar  of  each county, in order to receive
payment for fees or costs incurred by the  Department,  shall
present the Department with monthly statements indicating the
amount  of  fees and costs incurred by the Department and for
which no payment has been received.
    A notice of lien may be filed after  the  issuance  of  a
revised   final   assessment   pursuant  to  a  rehearing  or
departmental review under Section 4 or Section 5 of this Act.
    When the lien obtained pursuant  to  this  Act  has  been
satisfied and the taxpayer has paid the Department in cash or
by  guaranteed  remittance  an amount representing the filing
fee for the lien and the filing fee for the release  of  that
lien,  the  Department shall issue a release of lien and file
that release of lien with the recorder of  the  county  where
that lien was filed. The to the person, or his agent, against
whom  the  lien  was  obtained and such release of lien shall
contain in legible letters a statement as follows:
    FOR THE PROTECTION OF THE OWNER, THIS RELEASE SHALL
    BE FILED WITH THE RECORDER OR THE REGISTRAR
    OF TITLES, IN WHOSE OFFICE, THE LIEN WAS FILED.
    When a certificate of complete or partial release of lien
issued by the Department  is  presented  for  filing  in  the
office  of the recorder or Registrar of Titles where a notice
of lien or notice of jeopardy assessment lien was filed,  the
recorder,  in  the  case  of  nonregistered  property,  shall
permanently  attach  the certificate of release to the notice
of lien or notice of jeopardy assessment lien and shall enter
the certificate of release and the date  in  the  "State  Tax
Lien Index" on the line where the notice of lien or notice of
jeopardy assessment lien is entered.
    In  the  case  of  registered  property, the Registrar of
Titles shall file and enter upon each folium of the  register
of  titles  affected thereby a memorial of the certificate of
release which memorial when so entered shall act as a release
pro tanto of any memorial of such notice of lien or notice of
jeopardy assessment lien previously filed and registered.
(Source: P.A. 84-221.)

    (35 ILCS 120/5c) (from Ch. 120, par. 444c)
    Sec. 5c. Upon payment by the taxpayer to  the  Department
in cash or by guaranteed remittance of an amount representing
the  filing  fee  for  the  lien  and  the filing fee for the
release  of  that  lien,  the  Department   shall   issue   a
certificate  of  complete  or partial release of the lien and
file that complete  or  partial  release  of  lien  with  the
recorder of the county where the lien was filed:
    (a)  To  the  extent  that  the  fair market value of any
property subject to the lien exceeds the amount of  the  lien
plus the amount of all prior liens upon such property;
    (b)  To   the   extent   that   such  lien  shall  become
unenforceable;
    (c)  To the extent that the amount of such lien  is  paid
by  the  retailer  whose  property  is  subject to such lien,
together with any interest which may become due under Section
5 of this Act between the date when the  notice  of  lien  is
filed and the date when the amount of such lien is paid;
    (d)  To  the  extent  that  there  is  furnished  to  the
Department  on  a  form  to  be approved and with a surety or
sureties satisfactory  to  the  Department  a  bond  that  is
conditioned  upon  the  payment  of  the amount of such lien,
together with any interest which may become due under Section
5 of this Act after the notice of lien is filed,  but  before
the amount thereof is fully paid;
    (e)  To  the extent and under the circumstances specified
in Section 5a of this Act in the case of jeopardy  assessment
liens;
    (f)  To  the  extent  to  which  an assessment is reduced
pursuant to a rehearing or departmental review under  Section
4 or Section 5 of this Act.
    A  certificate of complete or partial release of any lien
shall be held conclusive that  the  lien  upon  the  property
covered  by  the  certificate  is  extinguished to the extent
indicated by such certificate.
(Source: Laws 1965, p. 531.)

    Section 99. Effective date. This Act  takes  effect  upon
becoming law, except that the changes to Sections 1102, 1103,
and  1105 of the Illinois Income Tax Act and Sections 5a, 5b,
and 5c of the Retailer's Occupation Tax Act  take  effect  on
January 1, 2003.
    Passed in the General Assembly June 02, 2002.
    Approved August 21, 2002.
    Effective August 21, 2002.
    Effective January 01, 2003.

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