In an order released in July 2021, the Illinois Tax Tribunal denied a taxpayerâs motion for summary judgment in a âunitary businessâ case, finding that there were disputed issues of fact as to whether the taxpayer was engaged in a unitary business with a company that the taxpayer sold. See Christopher v. Illinois Depât of Rev., 19 TT 131 (Ill. Tax Trib. Nov. 24, 2020, released July 2021). The taxpayer, T. Christopher Holding Company (âHolding Companyâ), claimed that it was not unitary with Vogue International, LLC (âOperating Companyâ), and thus its gain from the sale of Operating Company could not be included in Holding Companyâs Illinois business income under U.S. constitutional principles and Illinois law. However, the Tribunal found that the Illinois Department of Revenue (âDepartmentâ) had presented sufficient evidence to establish a disputed issue of material fact that rendered summary judgment on this issue inappropriate.
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