Appellate Court of Illinois December 31, 1992, 1-90-2988 (Liquid Air Corp. v. Johnson)

JUSTICE COUSINS

delivered the opinion of the court:

The resolution of this dispute turns on the proper construction of certain provisions of the Retailers’ Occupation Tax Act (ROTA) (Ill. Rev. Stat. 1989, ch. 120, par. 440 et seq.), which imposes a tax upon the gross receipts received by persons who sell tangible personal property at retail.