Does a hotel owe Hotel Operators' Occupation Tax on a guest's stay of more than 30 consecutive days when a different company took over paying the bill partway through, with no break in the stay?

Plain-English summary

This Illinois Private Letter Ruling addresses whether a hotel stay stops qualifying for the "permanent resident" exclusion from Hotel Operators' Occupation Tax when a different company takes over paying the bill partway through, even though the guest never leaves the room and the stay is never interrupted. The Department concluded that it does not: the tax exclusion turns on how long the guest continuously occupies (or has the right to occupy) the room -- at least 30 consecutive days -- not on who is paying the bill.

The taxpayer, a company that arranges temporary housing for insurance companies whose insureds have been displaced by property damage, described a case where an insured stayed at a hotel for 56 consecutive days. A different housing company paid the first 30 days of the stay, and the taxpayer then took over billing for the remainder, with no gap or interruption in the guest's occupancy. The hotel had refunded hotel tax to the first company for its 30 days, but then started charging hotel tax again once the taxpayer took over the billing, even though the same guest kept occupying the same arrangement without a break.

The Department ruled that the guest qualified as a "permanent resident" under 86 Ill. Adm. Code 480.101, because a permanent resident is any person who occupies or has the right to occupy a room (or rooms) in a hotel for at least 30 consecutive days, regardless of whether the person contracted for 30 days at check-in. Because the statute and regulations look at the guest's continuous occupancy rather than the identity of the payer, the hotel should not have charged (or sought reimbursement of) hotel tax for the disputed days -- it was not subject to the tax on those receipts at all, and the guest (or the party that ultimately bore the cost) has a legal right to claim a refund of any tax that was collected.

The ruling also restates the Hotel Operators' Occupation Tax Act's basic structure: the tax applies to gross rental receipts from renting hotel rooms, but receipts from renting to permanent residents are excluded. If a hotel does collect tax it isn't entitled to keep, and doesn't refund it to the guest, the hotel must remit that tax to the Department under 35 ILCS 145/3(f); once the hotel does issue an unconditional refund to the permanent resident, it may then file its own claim for credit under 86 Ill. Adm. Code 480.125.

What this means for you

Hotel operators

If a guest's stay is continuous and reaches 30 consecutive days, that guest is a "permanent resident" and your receipts for that room are excluded from Hotel Operators' Occupation Tax -- it does not matter whether the guest, an insurance company, a relocation/housing company, or some other third party is the one actually paying, and it does not matter whether that payer changes mid-stay. Charging hotel tax to a new payer who takes over billing mid-stay, when the guest's occupancy was never interrupted, is not supported by this ruling's reasoning. If you already collected tax you were not entitled to and did not refund it, you must remit it to the Department; if you refund it to the guest, you can then seek a credit.

Insurance claims administrators and relocation/housing companies

When you take over paying for an already-continuous hotel stay (for example, mid-claim on a homeowner's policy after property damage), this ruling supports treating the stay as tax-exempt once the 30-consecutive-day threshold is met, based on the guest's total time in the room -- not on which company is cutting the check at any given point. Keep records (folios, dates of occupancy, and documentation of the handoff between payers) showing the stay was continuous, since that continuity is what the Department relied on.

Accountants and tax professionals

The key regulatory hook is 86 Ill. Adm. Code 480.101's definition of "permanent resident" (occupancy or right to occupy for at least 30 consecutive days) together with 480.105's exclusion of those receipts from tax, as applied to a fact pattern where the payer -- but not the guest or the room -- changed mid-stay. Also relevant: 35 ILCS 145/3(f) (a hotel must remit any hotel tax it collects but does not refund) and 86 Ill. Adm. Code 480.125 (a hotel that does refund tax to a permanent resident may then claim a credit).

Common questions

Q: Does a hotel stay lose its "permanent resident" tax exclusion if a different company takes over paying the bill partway through?
A: No, according to this ruling. The Department found that the statute requires only that a person occupy or have the right to occupy a room for at least 30 consecutive days -- it does not require that the same entity pay for the entire period. The taxpayer's guest occupied the same hotel arrangement for 56 consecutive days even though billing shifted from one company to another, and the Department treated that as one continuous permanent-resident stay.

Q: Did the guest need to have a signed 30-day contract from day one to qualify?
A: No. The ruling states that regardless of whether the person contracted with the hotel operator to stay 30 consecutive days at check-in, if the person actually stays at least 30 consecutive days, the receipts for that period are excluded from tax.

Q: What should a hotel do if it already collected hotel tax it wasn't entitled to?
A: The person charged has a legal right to claim a refund of the tax from the hotel operator. Any tax collected that is not refunded to the customer must be remitted to the Department under 35 ILCS 145/3(f). If the hotel operator does issue an unconditional refund to the permanent resident, it may then file a claim for credit under 86 Ill. Adm. Code 480.125.

Q: Can my business rely on this ruling directly?
A: No, not automatically. This is a Private Letter Ruling issued under 2 Ill. Adm. Code 1200.110, and it binds the Illinois Department of Revenue only as to the specific taxpayer ("COMPANY") who requested it, and only to the extent the facts recited in the ruling are correct and complete. It also expires 10 years after issuance, or earlier if the underlying law or facts change. Other taxpayers can look to it as an illustration of the Department's reasoning, but they cannot rely on it as binding authority for their own situation -- a similar request or a General Information Letter would be needed for that.

Citations and references

Statutes and regulations:

• 35 ILCS 145/1 et seq. (Hotel Operators' Occupation Tax Act -- imposition of tax on gross rental receipts)
• 35 ILCS 145/3(f) (hotel operator must remit any collected tax not refunded to the customer)
• 86 Ill. Adm. Code 480.101 (definition of "permanent resident" -- occupancy for at least 30 consecutive days)
• 86 Ill. Adm. Code 480.105 (exclusion of permanent-resident receipts from Hotel Operators' Occupation Tax)
• 86 Ill. Adm. Code 480.125 (hotel operator's claim for credit after refunding tax to a permanent resident)
• 2 Ill. Adm. Code 1200.110 (Private Letter Ruling procedures, binding effect, and 10-year expiration)

Source

• Landing page: https://taxarchive.illinois.gov/research/legal/letter-rulings/sales-tax/2018.html
• Original PDF: https://tax.illinois.gov/content/dam/soi/en/web/taxarchive/research/legal/letter-rulings/sales-tax/2018/st-18-0009-plr.pdf

Original ruling text

ST 18-0009-PLR 08/20/2018

HOTEL OPERATORS’ TAX

Gross receipts from the rentals of rooms to "permanent residents" are not subject to Hotel
Operators' Occupation Tax liability. A "permanent resident" is any person who has occupied or
has the right to occupy any room or rooms in a hotel for at least 30 consecutive days. See 86
Ill. Adm. Code 480.101. (This is a PLR.)

August 20, 2018

Dear Xxxxx:
This letter is in response to your letter dated July 19, 2018, in which you requested information.
The Department issues two types of letter rulings. Private Letter Rulings (“PLRs”) are issued by the
Department in response to specific taxpayer inquiries concerning the application of a tax statute or
rule to a particular fact situation. A PLR is binding on the Department, but only as to the taxpayer
who is the subject of the request for ruling and only to the extent the facts recited in the PLR are
correct and complete. Persons seeking PLRs must comply with the procedures for PLRs found in the
Department’s regulations at 2 Ill. Adm. Code 1200.110. The purpose of a General Information Letter
(“GIL”) is to direct taxpayers to Department regulations or other sources of information regarding the
topic about which they have inquired. A GIL is not a statement of Department policy and is not
binding on the Department. See 2 Ill. Adm. Code 1200.120. You may access our website at
www.tax.illinois.gov to review regulations, letter rulings and other types of information relevant to your
inquiry.
Review of your request disclosed that all the information described in paragraphs 1 through 8
of Section 1200.110 appears to be contained in your request. This Private Letter Ruling will bind the
Department only with respect to COMPANY, for the issue or issues presented in this ruling, and is
subject to the provisions of subsection (e) of Section 1200.110 governing expiration of Private Letter
Rulings. Issuance of this ruling is conditioned upon the understanding that neither COMPANY, nor a
related taxpayer is currently under audit or involved in litigation concerning the issues that are the
subject of this ruling request. In your letter you have stated and made inquiry as follows:
I believe what I am looking for is a Private Letter Ruling in regards to a tax question
regarding tax exemption on hotel stays for 30+ continuous days.
COMPANY
(COMPANY’s Tax ID: ###) works as an intermediary between insurance companies
and their insureds securing temporary housing for the insureds when their home is
damaged and deemed unlivable until repairs are completed. COMPANY will pay for the
room and tax on such accommodations and will then invoice the insurance company for
those charges, so ultimately it is the insurance company footing the bill.
We recently had a client stay at the HOTEL at ADDRESS in CITY IL and what makes
this stay unique is that a different housing company (COMPANY 1) paid for the first 30
days (XX/XX/XX – XX/XX/XX) on the BANK CARD ending in xXXXX and then we took
over providing the accommodations for the insured from DATE – DATE and paid with
the BANK CARD ending xXXXX. I have included the entire folio of CLIENT’s stay at the
hotel for you to reference. In this situation the guest (CLIENT), the insurance company
(INSURANCE COMPANY), the hotel (HOTEL) did not change; only the temporary
housing changed from COMPANY 1 to COMPANY.

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The hotel did give a refund to COMPANY 1 for the first 30 days, but then starting
charging COMPANY tax when they took over billing even though there were no
interruptions in the stay. Based on my review of the tax code, I think the stay should
have remained tax exempt when COMPANY took over billing due to the following
information contained in: Illinois Department of Revenue Publication 106: Allowable
Deductions for IDOR-Collected Hotel Taxes. I have copied and pasted the publication
and the link for this publication is: http://www.revenue.state.il.us/Publications/Pubs/Pub106.pdf. To the best of my knowledge the taxpayer and the tax payer’s representative
the Department has not previously ruled on the same or a similar issue for the taxpayer
or a predecessor, or whether the tax taxpayer or any representatives previously
submitted the same or a similar issue to the Department but withdrew it before a letter
ruling was issued.
Illinois Department of Revenue Publication 106 Purpose: To explain to hotel operators
the deductions that are allowable under the hotel taxes collected by the Illinois
Department of Revenue. Objectives: To identify the hotel taxes that are collected by
the Illinois Department of Revenue To identify who is responsible for paying the hotel
taxes To identify allowable deductions under the hotel taxes To answer frequently
asked questions regarding hotel tax deductions Allowable Deductions for IDORCollected Hotel Taxes General Information: This publication explains the proper
reporting of allowable deductions for the hotel taxes collected by the Illinois Department
of Revenue (IDOR). Throughout this publication, the term “hotel tax” refers to all IDORcollected hotel taxes to which you are subject. What hotel taxes does the IDOR collect?
The IDOR collects the following state and Chicago area hotel taxes on Form RHM-1,
Hotel Operators’ Occupation Tax Return: State tax Illinois Hotel Operators’ Occupation
Tax (HOOT) Chicago are taxes Metropolitan Pier and Exposition Authority (MPEA)
Hotel Tax Chicago Municipal Hotel Tax (CMHT) Illinois Sports Facilities Tax (ISFT).
The IDOR does not collect any local hotel taxes other than the Chicago area taxes
listed above. All other local taxes are paid directly to the local taxing authority. Upon
whom are these taxes imposed? The state and Chicago area hotel taxes collected by
the IDOR are imposed on persons in the occupation of renting, leasing, or letting rooms
to the public for living quarters for periods of less than 30 days (i.e., hotel operators).
The HOOT is imposed on all hotel operators whose businesses are located in Illinois.
The CMHT and ISFT are imposed on hotel operators whose businesses are located in
the city of Chicago. The MPEA Hotel tax is imposed on hotel operators whose
businesses are located within the MPEA boundaries. Depending on the location of your
business, you may be subject to one or more of these hotel taxes. What deductions are
allowable under these taxes? You may take the following deductions on Form RHM-1:
local hotel tax paid directly to a local jurisdiction and not collected by the IDOR receipts
from permanent residents receipts from foreign diplomats receipts from student housing
not applicable to hotels receipts associated with display rooms, public rooms, sampler
rooms, meeting rooms, dressing rooms for swimming pools, offices, and private dining
rooms receipts from the sale of food and beverages receipts from the use of a
telephone receipts associated with barber shops, laundry services, vending services,
ticket sales, valet parking, garage rent, promotions, photos, magazines, and sundries
room adjustment charges, allowances, and discounts bad debts and uncollectables
intracompany sales refunds Each of these items is deductible under all IDOR-collected
state and Chicago area hotel taxes. If an item is not listed above, it most likely is not an
allowable deduction on Form RHM-1. Note: Receipts from the sale of food and

ST 18-0009-PLR
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beverages, prepaid phone cards, barber shop services, laundry services, vending
services, promotions, photos, magazines, and sundries may be subject to Illinois Sales
Tax. Are receipts from “no shows” deductible on Form RHM-1? No. When a guest
become liable for paying a charge to rent a room, the receipts from the rental are
subject to hotel tax, regardless of whether the person actually occupies the room. Do I
include all hotel taxes I collected on Form RHM-1, Line 1, Total receipts? Yes. You
must include all state, Chicago area, and local hotel taxes you collected in your total
receipts on Form RHM-1, Line 1. If you collected a local hotel tax, you may deduct that
tax on Line 2, Local tax deduction, because you pay it directly to the local jurisdiction.
You may not deduct the amount you collected for the MPEA Hotel Tax, CMHT, or ISFT
on Line 2. Who is a “permanent resident?” A permanent resident is a person who has
the right to occupy any room in a hotel for a least 30 consecutive days. PUB-106 (R1/08) Page 1 of 3 If I have a contract with a permanent resident, do I owe hotel tax for
the first 30 days of that guest’s stay? When you have a binding contract with a
permanent resident for at least 30 days, no hotel tax is due. However, if the contract is
terminated before the end of the first 30 days, you owe hotel tax for the period up to the
time when the contract was terminated. If a guest stays for 30 consecutive days or
more, has paid hotel tax, and later asks for a refund, what do I do? In this situation,
your guest has a legal right to request a refund of hotel tax paid. Therefore, you should
refund the amount of tax paid to your guest. If you do not refund the amount of tax paid,
you are liable to pay that amount to us. We do not refund hotel tax to hotel guests. If I
am unsure whether or not a guest is “permanent” at the end of the reporting period,
should I report and pay hotel tax on that guest’s stay? When you do not know whether
a guest is a permanent resident at the end of the period for which you are filing Form
RHM-1 because the guest’s first 30 days have not ended, you owe hotel tax on receipts
from that rental. If the guest later stays for 30 days, the receipts from that rental for the
first 30 days, or portion thereof, upon which you have already paid tax should be
deducted on Form RHM-1, step 2, Line 3, for the next month. Be sure to include a
breakdown with that month’s RHM-1 explaining the deduction. Who is a “foreign
diplomat?” A foreign diplomat is an official from a foreign country who is stationed in the
United States while working as a diplomat, consular officer, or staff member at a foreign
mission. This individual has been issued a tax emption card. Each card contains the
individual’s picture and either a blue, a green, a yellow, or a red stripe. A blue-striped
card exempts the individual from paying hotel tax. A red-striped card exempts the
individual from paying hotel tax over a minimum purchase amount listed on the face of
the card. A yellow-striped or green-striped card exempts the individual from paying
hotel tax unless hotels are listed as a restricted category on the face of the card, (e.g.,
exempt on purchases, exempt hotels). The United States Department of State, Office
of Foreign Missions, issues two types of exemption cards: A personal tax exemption
card is for use only by the individual named on the card. A mission tax exemption card
is for official use only. In order to receive the exemption, your guest must provide you
with proper identification. You must attach a copy of both sides of the tax-exempt card
to Form RHM-1 to be allowed to take receipts from the rental of a room to a foreign
diplomat as a deduction. Please indicate the color of the card on your return. If you do
not attach a copy of the card to the return, we will bill you for tax due, plus penalty and
interest. If a foreign diplomat is accompanied by visitors, are receipts from rentals to
those visitors also exempt form hotel tax? If a foreign diplomat has a blue-striped
mission card, red-striped mission card and is spending above the minimum purchase
amount listed on the card, or yellow-striped or green striped mission card that does not

ST 18-0009-PLR
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specifically restrict hotels, he or she may rent rooms on behalf of the mission and obtain
tax-exempt lodging for visitors or nonaccredited persons. The individual using the card
does not need to stay at the hotel. He or she may pay the hotel bill with a mission credit
card or a mission check, but may not use a personal credit card, check or cash. The
foreign diplomat may not use his or her personal tax exemption card to pay for hotel
rooms of those outside his or her immediate family. Where can I get more information
about foreign diplomats and tax exemption cards? If you would like more information
about foreign diplomats and their exemption from hotel tax, request a copy of Diplomatic
Tax Exemption Program by contacting: U.S. Department of State, Office of Foreign
Missions 77 West Jackson Blvd., Suite 2122 Chicago, IL 60604 Phone 312-353-5762
Fax: 312-353-5768 or writing to: Office of Legal Services (5-500) Illinois Department of
Revenue 101 West Jefferson Street Springfield, IL 62702 Are receipts from rentals to
federal, state, and local government employees exempt from hotel tax? No. Receipts
from rooms rented to federal, state, and local government employees are not exempt
from hotel tax. Being government employees does not exempt these individuals from
paying hotel tax. Are receipts from rentals to persons affiliated with schools or
charitable, religious, or other not-for-profit organizations exempt from hotel tax? No.
Receipts from rooms rented to individuals associated with these groups are not exempt
from hotel tax. Being associated with a school or not-for-profit organization does not
exempt these individuals from paying hotel tax. If a person or not-for-profit organization
presents a tax exemption certificate issued by the Illinois Department of Revenue to me,
are receipts from that rental exempt from hotel tax? No. A tax exemption certificate
issued by the Illinois Department of Revenue exempts certain entities from Illinois Sales
Tax, not hotel tax. Page 2 of 3 PUB-106 (R-1/08) Allowable Deductions for IDORCollected Hotel Taxes Call us at 217-782-6045. Call our TDD (telecommunications)
device for the deaf) at 1 800 544-5304. Write us at Illinois Department of Revenue,
Miscellaneous Taxes Division P.O. Box 19477, Springfield, IL 62794-9477. Visit our
website at tax.illinois.gov. Call our 24-hour Forms Order Line at 1 800 356-6302. For
information or forms printed by authority of the State of Illinois (605- copies – 1/08 –
P.O. number 2080460). Because of confusion on this issue, we have revised
exemption certificates to specifically state that the organization is not exempt from the
hotel tax. I operate a private club and rent rooms only to club members and their
guests. Am I exempt from paying hotel tax? Since hotel tax is limited to the renting of
rooms to the public and your club restricts its renting of rooms to members and their
guests, you are not liable for hotel tax on your rental receipts from such rooms. Are
schools that rent rooms to students are living quarters subject to hotel tax? A school is
not subject to hotel tax on receipts from renting rooms to its students for use as living
quarters, or for sleeping or housekeeping accommodations, because these are not
rentals to the public. If the school rents rooms for such purposes to persons who are
not enrolled with the school in courses of study for credit, such renting is being made to
the public. Therefore, the school owes hotel tax on receipts from such rentals, as long
as the person does not qualify as a permanent resident. If a guest requests a roll-away
bed, are receipts from the rental of the bed subject to hotel tax? Yes. Receipts from
the rental of the rollaway bed are subject to hotel tax. If you make a separate and
specific charge for the use of bedding or other facilities furnished in connection with the
use of a room as living quarters or for sleeping or housekeeping accommodations, the
receipts from this source are subject to hotel tax. Are receipts from meeting or banquet
rooms subject to hotel tax? No. Since hotel tax is imposed on receipts from renting
rooms for living quarters or for sleeping or housekeeping accommodations, the tax does

ST 18-0009-PLR
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not apply to receipts from the renting of rooms for other purposes (e.g., for use as
display rooms, sample rooms, meeting rooms, offices, or private dining rooms). If I
operate a bed and breakfast and do not include the breakfast in the room rate, are
receipts from the breakfast subject to hotel tax? No. The receipts you receive from
selling food, beverages, or other tangible personal property are not subject to hotel tax.
If you provide complimentary food to your guests and do not operate a restaurant that is
open to the public, you must pay Illinois Use Tax on the food items when they are
purchased. If you sell food to your guests and operate a restaurant that is open to the
public, your receipts are subject to Illinois Sales Tax. You must be registered
separately with us to report and pay sales tax on these items. Are “in-room movies”
subject to hotel tax? Receipts for movie rentals are not subject to hotel tax if you are
not the entity that actually provides the movie, authorize a movie vendor to install
equipment in the rooms and sell movies to your guests, and merely collect the money
for the movie vendor. However, if you actually provide movies to your guests, these
receipts are subject to hotel tax. What if a person or organization refuses to pay hotel
tax? As a hotel operator, the liability for paying hotel tax falls upon you, not your guests.
You may, however, pass hotel taxes to which you are subject on to your guests as
separately stated items on your guests’ bills. If you do not pay the tax liability on Form
RHM-1, you will be assessed for the tax due, plus penalty and interest. Will I be
penalized if I fail to properly identify a deduction I claim on Form RHM-1? If you do not
properly identify a deduction you claim on Form RHM-1, we will automatically assess
you for the tax due, plus penalty and interest. If the deduction is allowable, you must file
an amended Form RHM-1 identifying the allowable deduction you are claiming. If after
reviewing your return, we determine the deduction is allowed, we will withdraw the
assessment in full. If we determine the deduction is not allowed, you will owe the full
assessment. How can I correct an error made on my return? If you made an error on
your Form RHM-1 (e.g., failed to claim an allowable deduction), you must file an
amended return to correct the error. (To file an amended return, use form RMH-1 and
check the “amended” box.) You must pay any additional tax due. Penalty and interest
will be due on the additional tax if you do not file the amended return and pay the
additional tax due by the due date of the original return. If your amended return shows
you have overpaid tax, you must indicate this fact and request a refund or credit.
Questions? If you have questions or need more information, please call or write us.
Our telephone numbers and address are listed at the end of the publication.
If any additional information is needed, please do not hesitate to contact me.
DEPARTMENT’S RESPONSE:
The Hotel Operators’ Occupation Tax Act (35 ILCS 145/1 et seq.) imposes a tax upon persons
engaged in the business of renting, leasing or letting rooms in a hotel. The tax is imposed at a rate of
5% of 94% of the gross rental receipts from the renting, leasing or letting of such rooms. An additional
tax is also imposed at a rate of 1% of 94% of such gross rental receipts. The gross proceeds from
rental receipts for rentals to “permanent residents” are excluded from Hotel Operator’s Occupation
Tax liability.
A permanent resident is any person who occupies or has the right to occupy any room or
rooms, regardless of whether it is the same room or rooms, in a hotel for at least 30 consecutive

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days. See 86 Ill. Adm. Code 480.101 and 480.105. Regardless of whether the person contracted with
the hotel operator to stay 30 consecutive days at check-in, if a person qualifies as a permanent
resident (stays at least 30 consecutive days at the hotel), the gross receipts received by the hotel
operator would not be subject to tax for that period.
If the hotel operator charges a person the hotel tax for a room (whether or not it is the same
room) for at least a 30-consecutive day period, the person shall have a legal right to claim a refund of
the amount of tax collected for such room from the hotel operator.
Any taxes collected by the hotel operator that are not refunded to the customer for any reason
must be remitted to the Department. 35 ILCS 145.3(f). Upon an unconditional refund of the tax to the
permanent resident, the hotel operator may file a claim for credit for any hotel tax paid by the
operator. 86 Ill. Adm. Code 480.125.
Based upon the facts in your letter, your client occupied a room in a HOTEL for a total of 56
consecutive days (checking in on DATE, 20XX and checking out on DATE, 20XX). As noted above,
the statute provides that to be considered a permanent resident, a person must occupy or have a
right to occupy any room for at least 30 consecutive days. Your client occupied a room in a HOTEL
for 56 consecutive days and should have been considered a permanent resident. As such, the
HOTEL was not subject to the Hotel Operator’s Tax with respect to the rental receipts for those 56
days and, thus, should not have sought reimbursement of the tax from your client. The statute does
not require that the payment for a room be by the same entity for at least 30 consecutive days, only
that a person occupy or have the right to occupy a room for at least 30 consecutive days.
The factual representations upon which this ruling is based are subject to review by the
Department during the course of any audit, investigation, or hearing and this ruling shall bind the
Department only if the factual representations recited in this ruling are correct and complete. This
Private Letter Ruling is revoked and will cease to bind the Department 10 years after the date of this
letter under the provisions of 2 Ill. Adm. Code 1200.110(e) or earlier if there is a pertinent change in
statutory law, case law, rules or in the factual representations recited in this ruling.
I hope this information is helpful. If you have further questions concerning this Private Letter
Ruling, you may contact me at (217) 782-2844. If you have further questions related to the Illinois
sales tax laws, please visit our website at www.tax.illinois.gov or contact the Department’s Taxpayer
Information Division at (217) 782-3336.
Very truly yours,

Richard S. Wolters
Chairman, Private Letter Ruling Committee
RSW:DMB:bkl