morris complaint (03.19.14)

8/12/2019 Morris Complaint (03.19.14)

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Fuels actual business of selling in this state occurs within Morris. In reality, Bell Fuels conducts

its sales within the RTAs taxing jurisdiction in Stickney, Illinois Bell Fuels and its employees thus

enjoy the benefits of the RTAs transportation services in Stickney without contributing their fair

share of sales taxesall at great expense to the citizens and law abiding taxpayers living and

doing business there. This scheme deprives the RTA of its portion of sales tax revenues

necessary to fund its continued operations.

4. A recent Illinois Supreme Court case, Hartney Fuel Oil Company, et al. v. Hamer, et

al., 2013 IL 115130, 36, 998 N.E.2d 1227, Ill. 2013 (Hartney), reaffirmed that the business of

selling under local retailers occupation taxes (local ROT Acts) is a fact-intensive composite of

many activities and the legislative intent for enacting local ROT Acts was to allow local

jurisdictions to tax the composite of selling activities taking place within their jurisdictions,

collecting taxes in relation to services enjoyed by the retailer. The Hartney decision invalidated

the Illinois Department of Revenues (IDORs) rules governing retailers occupation taxes

imposed by local jurisdictions.

5. In the wake of Hartney , the IDOR issued emergency rules on January 22, 2014,

which declare that mere retail order acceptance does not by itself constitute the business of

selling for taxing purposes (the Rules). A copy of the Rules is attached as Exhibit A, 86 Ill.

Adm. Code 320.115 (amended by emergency rulemaking at 38 Ill. Reg. ____, effective Jan. 22,

2014 for a maximum of 150 days). The Rules set forth guidance on the application of Hartney s

composite of selling activities test in various circumstances. The Rules list nine factors that are

to be used to determine whether a seller is engaged in the business of selling in a particular

Illinois taxing jurisdiction. Id. at 320.115(c)(1)-(3). According to the Rules, each of these factors


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must be viewed in light of the overarching principle that the retailer incurs local retailers

occupation tax in the jurisdiction where it enjoyed the greater part of governmental protection

[and] benefitted by being conducted under that protection. Id. at 320.115(c)(4)(A).

6. The practices complained of herein violate an Illinois law that has been in place

for 40 years.

7. On March 5, 2014, attorneys for the RTA sent a letter to the Defendant Retailer by

certified mail, fax, and e-mail advising that the RTA had reason to believe that the Retailer was

engaging in selling activities within the RTAs jurisdiction. The letter requested specific

information relating to the Retailers operations in the State of Illinois so the RTA could assess

whether the RTA was receiving all of the tax revenue to which it was entitled. A copy of the

letter is attached as Exhibit B.

8. The letter specifically stated that it was sent in an attempt to avoid litigation and

that if there was no response by March 13, 2014, the RTA would take the necessary actions to

protect its rights. The letter invited a call to the RTAs attorneys to discuss the matter. As of the

time of filing this complaint, the Defendant Retailer has not contacted the RTA or its attorneys in

response to the March 5, 2014 letter.

9. This action is brought to require the Defendant Retailer to pay taxes in the proper

jurisdiction, to recover statutory damages from the Defendant municipality, and to obtain

appropriate and full monetary and equitable relief from both of the Defendants.


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PARTIES

10. The RTA is a special purpose unit of local government and municipal corporation

created by Illinois law. The RTAs primary responsibility is the financial and budget oversight of

the Chicago Transit Authority, the Commuter Rail Division of the RTA (Metra), the Suburban Bus

Division of the RTA (Pace), and regional transit planning initiatives. The RTA is the third largest

public transportation system in North America, providing more than two million rides per day,

and its system covers 7,200 route miles in a six-county region with a population of

approximately eight million people. The six counties comprising RTAs taxing jurisdiction are

Cook, DuPage, Kane, Lake, McHenry, and Will. RTA is funded, in part, through the Regional

Transportation Authority Retailers Occupation Tax pursuant to the Regional Transportation

Authority Act (the RTA Act), 70 ILCS 3615/4.03(e).

11. Defendant Morris is a non-home rule municipal corporation located in Grundy

County, Illinois.

12. Defendant Bell Fuels, a Nevada corporation, is one of the largest and most

recognized independent fuel distributors in the Midwest. Bell Fuels maintains administrative

offices, a truck dispatch office, accounting and maintenance facilities, as well as retail and/or

warehouse facilities at its facility on Pershing Road (39 th Street) in Stickney, Cook County, Illinois.

Bell Fuels provides uninterrupted diesel fuel for truck fleets through its supply connections with

Exxon-Mobil, Marathon, Valero, Citgo and BP and its own 1.5 million gallon storage capacity.

Bell Fuels also claims to be the largest heating oil distributor in the Chicago metropolitan area.


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JURISDICTION AND VENUE

13. This Court has jurisdiction over Morris pursuant to 735 ILCS 5/2-209 because it is

a resident of, and transacts business within, the State.

14. Venue is proper in the Circuit Court of Cook County pursuant to 735 ILCS 5/2-

101, 5/2-102, and 5/2-103 because it is the county where the Defendants activities described

herein inflicted damage, and because it is the county in which all or part of the transaction

giving rise to the causes of action described herein occurred.

FACTUAL ALLEGATIONS

Sales Tax Background

15. Illinois sales tax is imposed upon retailers at a rate of 6.25% pursuant to the

Illinois Retailers Occupation Tax, 35 ILCS 120/1 et seq. Municipalities receive a Local Share of

the statewide 6.25% tax, which presently equals 1.0% of the sale price. See 35 ILCS 120/3; 30

ILCS 105/6z-18. The State also authorizes home rule county governments, home rule municipal

governments, and the RTA to impose their own local retailers occupation taxes through the

Home Rule County Retailers Occupation Tax Law (55 ILCS 5/5-1006), the Home Rule Municipal

Retailers Occupation Tax Act (65 ILCS 5/8-11-1), and the RTA Act (together referred to as the

local ROT Acts).

16. The local ROT Acts allow these government entities to levy retail occupation taxes

upon all persons engaged in the business of selling tangible personal property at retail within

the county, municipality, or metropolitan region. 55 ILCS 5/5-1006; 65 ILCS 5/8-11-1; 70 ILCS

3615/4.03(e).

17. The RTA Act contains a statement of legislative purpose, describing public


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transportation as an essential public purpose as follows:

There is an urgent need to reform and continue a unit of localgovernment to assure the proper management of publictransportation and to receive and distribute State or federal

operating assistance and to raise and distribute revenues for localoperating assistance. System generated revenues are notadequate for such service and a public need exists to provide for,aid and assist public transportation in the northeastern area of theState, consisting of Cook, DuPage, Kane, Lake, McHenry and WillCounties.

70 ILCS 3615/1.02(a)(i).

18. The Illinois Supreme Court recently made clear the legislative intent of the RTA

Act: such taxes are to be collected in part because the revenues generated by public

transportation are insufficient to support that essential public purpose in Cook, DuPage, Kane,

Lake, McHenry, and Will Counties. Hartney , 2013 IL 115130, 29, 998 N.E.2d 1227, 1236 Ill.

2013.

19. The RTA Act thus imposes a sales tax upon the business of selling in the

aforementioned six counties comprising the Chicago metropolitan region and RTAs taxing

jurisdiction. 70 ILCS 3615/4.03(e).

20. The State of Illinois, by law, also provides to the RTA additional annual funding

equal to 30% of its sales tax revenue as a match on sales made in the sixcounty RTA region.

See, e.g., 70 ILCS 3615/4.03.

21. In Illinois, the location of the business of selling determines which local

governmental units receive the local share of the statewide tax on retail sales. Thus,

municipalities are highly motivated to attract retailers to their communities to garner the

resulting sales tax revenue.


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22. The IDOR collects all sales taxes paid by retailers and remits to local government

units their respective shares.

Sales Tax Schemes and the 2004 Statutory Change

23. In an attempt to take advantage of different municipalities combined sales tax,

certain municipalities, brokers, and/or retailers, beginning as early as 2000, attempted to make it

appear that sales transactions occurred in lower-taxed jurisdictions when, in fact, they took place

in other, higher-taxed jurisdictions. These brokers and retailers asserted that the situs of the

retailers sales should be at the location of purported sale acceptance, even if the retailers

business of selling occurred elsewhere. The entities opened sham sales offices in low tax

areas while the subject retailers actually conducted their predominant selling activity in higher-

taxed locales.

24. In light of the prevalence of such kickback schemes and the harm they caused to

municipal corporations, the Illinois legislature took action. The General Assembly passed a

statute prohibiting certain retailers and municipalities from entering into retail sales tax rebate

agreements after June 1, 2004 where such agreements deprived other government units of sales

tax revenue. 65 ILCS 5/8-11-21 (the 2004 Statute). Said statute recites in part:

Sec. 8-11-21. Agreements to share or rebate occupation taxes.

(a) On and after June 1, 2004, the corporate authorities of a municipality shall notenter into any agreement to share or rebate any portion of retailers' occupationtaxes generated by retail sales of tangible personal property if: (1) the tax on

those retail sales, absent the agreement, would have been paid to another unit of local government; and (2) the retailer maintains, within that other unit of localgovernment, a retail location from which the tangible personal property isdelivered to purchasers, or a warehouse from which the tangible personalproperty is delivered to purchasers. Any unit of local government denied retailers'occupation tax revenue because of an agreement that violates this Section mayfile an action in circuit court against only the municipality. Any agreement


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entered into prior to June 1, 2004 is not affected by this amendatory Act of the93rd General Assembly. Any unit of local government that prevails in the circuitcourt action is entitled to damages in the amount of the tax revenue it wasdenied as a result of the agreement, statutory interest, costs, reasonableattorney's fees, and an amount equal to 50% of the tax.

25. This statute is intended to prohibit one jurisdiction from poaching retailers from

another for sales tax purposes utilizing tax rebates, while the former jurisdiction still retains a

retail or warehouse location from which tangible personal property is delivered to purchasers.

26. Despite said statute, some retailers and brokers entered into tax rebate

agreements or renewed existing agreements with low-tax municipalities even after the effective

date of the 2004 statute.

27. Many of the said retailers are located within the RTAs taxing jurisdiction and/or

deliver their retail products to customers from retail or warehouse locations within the RTAs

taxing jurisdiction where the retailers engage in the business of selling, and their sales are or

should be subject to the RTAs sales taxes.

28. As a direct result, the RTA is deprived of significant sales tax revenue.

Economic Incentive Agreement Between Morris and Bell Fuels

29. In the case at issue in this complaint, Bell Fuels, which is located within the

higher-taxing community of Stickney, entered into a contract called an Economic Incentive

Agreement (EIA) with the lower-taxing municipality of Morris. A copy of the EIA is attached as

Exhibit C.

30. The community of Stickney is located within RTAs taxing jurisdiction. Its

combined sales tax rate is 9.00%, whereas Morris combined sales tax rate is only 6.25%.

31. Pursuant to the EIA, Bell Fuels opened a small sales office in Morris which


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commenced operations on or about October 15, 2001. See Exhibit C, Section 2, A. This sales

office in Morris had little, if any, decision-making authority and did not conduct the business

of selling. According to the EIA, the sales office merely served as a single order acceptance

point for all Illinois credit sales except for Chicago-area heating oil sales. Id.

32. In return for Bell Fuels establishment of its sales office, Morris agreed to pay

Bell Fuels a rebate of seventy percent (70%) of the sales tax revenue paid to it by the IDOR for

the purported sales conducted by Bell Fuels at its sham sales office. Exhibit C, Section 3.

33. The EIA provided for a ten-year term, but further provided that it will be

automatically renewed for two (2) additional terms of five (5) years each . . . unless either party

provides the other party written notice not to renew . . . Exhibit C, Section 8, B. A Rebate

Sharing Agreement Web Application on file with the IDOR states that the Morris-Bell Fuels EIA

is in effect until November 15, 2021. Obviously, neither Morris nor Bell Fuels took any action to

cancel the EIA after its initial ten-year term expired in 2011, even after passage of the 2004

Statute. A copy of the Rebate Sharing Agreement Web Application is attached as Exhibit D.

34. Bell Fuels and Morris realized significant financial benefits from this arrangement.

Bell Fuels paid a lower sales tax rate than it would have paid in Stickney and also received

substantial revenue from Morris sales tax rebate (all without truly changing its operations in any

material fashion). At the same time, Bell Fuels required virtually no municipal services for its

small sales office in Morris, since its primary sales operations and staff where it actually

engaged in the business of selling remained within RTAs taxing jurisdiction.

35. Morris received an unjustified windfall in sales tax revenue without incurring the

expense of providing municipal services to Bell Fuels.


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36. Meanwhile, the RTA, the Town of Stickney and Cook County were left with the

burden of continuing to provide services to Bell Fuels and its employees without receiving the

sales taxes necessary and appropriate to support such services.

The Hartney Decision and Emergency Rulemaking

37. The Illinois Supreme Court in Hartney Fuel Oil Company v. Hamer , 2013 IL

115130, 998 N.E.2d 1227, Ill. 2013 analyzed the question of the proper situs for sales tax liability

under the local ROT Acts. In its November 21, 2013 decision, the court concluded that the

location of the business of selling under the local ROT Acts is a fact-intensive composite of

many activities. Hartney , 21013 IL 115130 at 36.

38. With this principle in mind, the Supreme Court examined the administrative

regulations governing situs of the local ROT Acts, namely the Jurisdictional Questions sections

found in the regulations pertaining to home rule counties (86 Ill. Adm. Code 220.115), home

rule municipalities (270.115), and the RTA (320.115). The court found that these regulations

erroneously treated the situs of sellers acceptance of purchase orders or other contracting

actions as the most important single factor in determining the location of sales activity.

Hartney , 2013 IL 115130 at 45-56. This treatment was inconsistent with the fact-intensive

composite of many activities test mandated by the local ROT Acts and Supreme Court

precedent and was thus too inconsistent with the statutes and case law to stand. Hartney ,

21013 IL 115130 at 57-64.

39. On January 22, 2014 the IDOR issued the aforementioned Rules to replace the

Jurisdictional Questions regulations invalidated by the Hartney decision. Exhibit A, 86 Ill. Adm.

Code 320.115 (amended by emergency rulemaking at 38 Ill. Reg. ____, effective Jan. 22, 2014 for


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a maximum of 150 days). The Rules took effect upon issuance and are to be treated as law as of

that date.

40. The Rules specifically declare that, with few exceptions, mere retail order

acceptance does not by itself constitute the business of selling under the local ROT Acts. See

Exhibit A, 86 Ill. Adm. Code 320.115(b)(8)(A). They also provide guidance on the application of

the Hartney composite of selling activities test. See Exhibit A, 86 Ill. Adm. Code 320.115(b)-(c).

41. For typical retailers, such as those conducting over-the-counter sales of tangible

personal property in which the purchaser takes possession of the property immediately or the

seller ships the property to the purchaser from the location where the sale was made, the Rules

dictate that the business of selling occurs in the jurisdiction where the over-the-counter sale

occurred. Exhibit A, 86 Ill. Adm. Code 320.115(c)(2).

42. For sellers whose particular retail operations make determining sales tax situs

more difficult, the Rules set forth four Primary Factors and five Secondary Factors for

determining the true location of the business of selling. The Primary Factors are: A) the

location of officers, executives and employees with discretion to negotiate on behalf of, and to

bind, the seller; B) the location where offers are prepared and made; C) the location where

purchase orders are accepted or other contracting actions that bind the seller to the sale are

completed; and D) the location of inventory if tangible personal property that is sold is in the

retailers inventory at the time of its sale or delivery. Exhibit A, 86 Ill. Adm. Code 320.115(c)(2).

43. The Rules caution that the Secondary Factors are only to be considered if the

Primary Factors fail to resolve the question of situs. Exhibit A, 86 Ill. Adm. Code 320.115(c)(3).

They are: A) the location where marketing and solicitation occur; B) the location where purchase


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orders or other contractual documents are received when purchase orders are accepted,

processed, or fulfilled in a location or locations different from where they area received; C) the

location of the delivery of the property to the purchaser; D) the location where title passes; and

E) the location of the retailers ordering, billing, accounts receivable and other administrative

functions. Exhibit A, 86 Ill. Adm. Code 320.115(c)(3).

44. Pursuant to the Rules, determining sales tax situs must be performed in keeping

with the principle that the retailer incurs local retailers occupation tax in the jurisdiction where

it enjoyed the greater part of governmental protection [and] benefitted by being conducted

under that protection. Exhibit A, 86 Ill. Adm. Code 320.115(c)(4)(A).

45. It is clear that Hartney s fact-intensive approach for determining the situs of the

business of selling controls application of the local ROT Acts.

COUNT ICLAIM FOR LOST REVENUES UNDER 65 ILCS 5/8-11-21 (the 2004 Statute)

The RTA v. Morris

46. RTA repeats and realleges paragraphs 1-45 above as paragraphs 1-45 of this

Count I.

47. Morris allowed the aforesaid EIA with Bell Fuels to automatically renew after the

effective date of the 2004 Statute.

48. Morris thus violated the 2004 Statute because:

a. Absent renewal of the agreement, Bell Fuels would not have paid andwould not be paying sales taxes in Morris but would have paid or bepaying taxes in one or more of the municipalities contained within RTAstaxing jurisdiction; and

b. On information and belief, Bell Fuels maintains retail or warehouselocations within RTAs taxing jurisdiction from which tangible personalproperty is delivered to purchasers.


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49. By reason thereof, RTA has and is suffering loss and Morris is liable to RTA for

damages in the amount of the tax revenue it was denied as a result of the said EIA after passage

of the 2004 Statute, statutory interest, costs, reasonable attorneys fees, and an amount equal to

fifty percent of the lost tax consistent with 65 ILCS 5/8-11-21.

50. RTA does not know the exact amount of sales tax received by Morris and thus

denied to RTA from the said EIA after passage of the 2004 Statute. However, such sums shall be

determined in the course of discovery in this case.

WHEREFORE, the Plaintiff, REGIONAL TRANSPORTATION AUTHORITY, requests this

Court to enter judgment in its behalf and against the Defendant, CITY OF MORRIS, for an

amount equal to the amount of tax revenue each was denied as a result of said violation of 65

ILCS 5/8-11-21, plus statutory interest, costs, reasonable attorneys fees and an amount equal to

fifty percent of such lost tax, and for such other and further relief as the Court deems proper.

COUNT IICLAIM FOR DAMAGES AND EQUITABLE RELIEF (post- Hartney decision)

The RTA v. Morris and Bell Fuels

51. RTA repeats and realleges paragraphs 1-45 above as paragraphs 1-45 of this

Count II.

52. Morris entered into an EIA with Bell Fuels. The activity conducted by Bell Fuels in

Morris under the EIA purportedly consists of accepting sales purchase orders and possibly other

minor related activities. Such actions do not constitute the business of selling by the retailer

pursuant to Hartney , 2013 IL 115130, 998 N.E.2d 1227, Ill. 2013, and the Rules.

53. Due to the EIA, Bell Fuels, on information and belief, misreported tax situs. Bell

Fuels reported Morris as the situs of their tax sales when in fact their business of selling was


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( h ) gr a n t s uc h o t he r a n d f u r t h e r r e l i e f a s t h e Cou r t d e e ms p r o p er .

P LAI NTI F F D E MA N D S A RI AL B Y A J U R Y O F T W E L V E 1 2 ) N L L C O U N T S N D S S UES TRI ABLE B Y A J U R Y

Th e RE G I O NA L T R A N S P O R T A T I O N AUTHORI TY,a n I l l i n o i s s pe c i a l pu r po s e u n i t o f

g o v e r n me n t a n d mu ni c i p al c o r p or a t i o n

By :

HEYL, ROYS TER, V E , K ALLENTi mo t h y L Be r t s c hy , A R D C 1 9 9 9 3 1

J o h n P. He i l r . A R D C 62 3 7 28 6Ma u r y Yu s o f , A R D C 6 2 7 8 7 6 7

Al e x S . Ke t a y , A R D C 6 3 1 3 2 2 01 9 . L a Sa e t r e e t Su i t e 1 2 03

Ch ic a go , L 6 0 6 0 3Te l e p ho n e : 3 12 . 85 3 . 8 7 10Fa s m e : 31 2 .7 8 2 . 0 0 4 0

a n d1 2 4 S W d a m s t r e e t Su i t e 6 0 0

P eo r i a I L 6 1 6 0 2Te l e p h o n e : 3 0 9 . 6 7 6. 0 4 0 0

Fa c s i m e : 3 09 . 67 6 .3 3 74C o o k C ou n t y Fi r m No .

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IN T H E I RCUI T C O U R T O F C O O K C O UN T Y , LLI NOI SC O U N T Y D E P A R T ME N T , H A N C E R Y I VI S IO N

Th e R E G I O N A L T R A N SP O R TA T I O N }AUTHORI TY n l l i n o i s s p e c i a l p u r p o s e un i t o f g o v e r n me n t a n d m un i c i p a l c o r p o r a t i o n ,

P la in ti f f

vs . Ca s e No .

Th e C I TY OF MORRI S n l l i n o i s n o n h o me r u l e muni c i pa l i t y , a n d BELL FUELS, NC. ,

Def e n d an ts

I LLI NOI S S U P R E ME C O U R T R UL E 2 22 ( b ~ AF F I DAVI T

Ma u r y Y us o f , h a v i n g b e e n d u l y s wo r n a n d u p o n o a t h , s t a t e s a s f o l l ows :

1 . I a m c o mp e t e n t t o t e s t i f y c o n c er n i n g t h e ma t t e r s c o n t a i n e d i n t hi s A ff i d av i t .

2 . As a t t o r n ey f o r t h e P la in ti f f I h a v e r e v i e we d t h e f a c t s o f t h i s c a s e a n d h a v e d e t e r mi n e d

t h e t ot a l a mo u n t o f mo n e y d a ma g e s s o u g h t e x c e e d s i ft y t h o us a n d dol l a r s a n d 0 0 /1 0 0

c e n t s ( 0 , 0 00 . 0 0 .

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S E N D A L L P L E A D I N G S T O :

HE YL, ROYS TER VOELKER A L L E N1 2 4 S W A d a m s t r e e t , Su i t e 6 0 0

P eo r i a , I L 6 1 6 0 2

Te l e p h o n e : 3 9 .6 7 . 0 4 0 0Fa c s i mi l e : 3 0 9 6 7 6 33 7 4

Fi r m No . 1 5 68 3

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morris complaint (03.19.14)

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