Buchanan Energy (N) LLC v. County of Cook

2024 IL App (1st) 220056, 251 N.E.3d 463
CourtAppellate Court of Illinois
DecidedMarch 22, 2024
Docket1-22-0056
StatusPublished

This text of 2024 IL App (1st) 220056 (Buchanan Energy (N) LLC v. County of Cook) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Buchanan Energy (N) LLC v. County of Cook, 2024 IL App (1st) 220056, 251 N.E.3d 463 (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 220056 FIFTH DIVISION MARCH 22, 2024

No. 1-22-0056

______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

______________________________________________________________________________

BUCHANAN ENERGY (N) LLC, ) Appeal from the ) Circuit Court of Plaintiff-Appellee and Cross-Appellant, ) Cook County. ) v. ) No. 20 L 50500 ) THE COUNTY OF COOK, an Illinois County, THE ) COOK COUNTY DEPARTMENT OF ) ADMINISTRATIVE HEARINGS, and THE COOK ) Honorable COUNTY DEPARTMENT OF REVENUE, ) John J. Curry Jr., Defendants-Appellants and Cross-Appellee. ) Judge Presiding. ______________________________________________________________________________

JUSTICE LYLE delivered the judgment of the court, with opinion. Presiding Justice Mitchell and Justice Mikva concurred in the judgment and opinion.

OPINION

¶1 On January 24, 2017, the defendants-appellants, the Cook County Department of Revenue

(the Department) and County of Cook, issued two notices of tax determination and assessment

against the plaintiff-appellee, Buchanan Energy (N) LLC (Buchanan North), pertaining to failures

to pay the gasoline tax and diesel fuel tax. On September 28, 2020, the Department of

Administrative Hearings issued a written ruling, finding that Buchanan North owed Cook County

approximately $69,632.73 for unpaid gasoline tax and $4,366.06 for unpaid diesel fuel tax.

Buchanan North appealed the administrative decision to the circuit court. The circuit court No. 1-22-0056

reversed the order in part and vacated in part, finding that Buchanan North was only responsible

for taxes on the fuel delivered to Buchanan Energy (S) LLC (Buchanan South). The defendants,

County of Cook and the Department, filed their notice of appeal. After the defendants filed their

notice of appeal, Buchanan North filed their notice of a cross-appeal. On appeal, defendants argue

that the Department of Administrative Hearings correctly concluded that Buchanan North was

liable for failing to collect Cook County’s fuel tax. On cross-appeal, Buchanan North argues that

the circuit court erred by finding a taxable transaction occurred when fuel was transferred to

Buchanan South. For the reasons that follow, we affirm the judgment of the circuit court of Cook

County and vacate the order of the ALJ.

¶2 I. BACKGROUND

¶3 Buchanan North has been a registered distributor of gasoline and diesel fuel in Cook

County since 2011. The Department performed an audit of the fuel tax paid by Buchanan North

between January 1, 2009, through August 31, 2016, even though it had not begun operations during

the first couple of years of the timeframe of the audit. At the end of the audit, on January 24, 2017,

the Department issued two notices of tax determination and assessment with one pertaining to

gasoline tax and the other to a diesel fuel tax. In the notices, the Department included an assessment

of the taxes owed as well as interest, late payment penalties, and willfulness or negligence

penalties. For the gasoline notice, the Department sought $84,144.63, along with interest and

penalties, totaling $182,677.05. With respect to the diesel fuel notice, the Department sought

$4,366.06, along with interest and penalties, totaling $8,620.04. In response to the notices, on

February 9, 2017, Buchanan North filed a written protest and petition for hearing.

¶4 On November 29, 2018, an administrative law judge (ALJ) of the Department of

Administrative Hearings heard testimony from witnesses which continued on three other days,

-2- No. 1-22-0056

ending on September 23, 2019, along with receiving documentary evidence and affidavits. In the

hearings, the ALJ received evidence that Steven Buchanan owned several business entities,

including Buchanan North and Buchanan South. Buchanan North was a registered distributor in

Cook County and distributed gasoline and diesel fuel to various gas stations in Cook County,

including those owned by Buchanan North and Buchanan South. Mr. Buchanan also owns another

business entity called Buck’s, Inc. of Collinsville (Buck’s), which was created under Illinois law.

Buck’s employed the individuals working at Buchanan North and Buchanan South. Using their

own tanker trucks, Buck’s also picked up gasoline and diesel fuel from Buchanan North’s storage

facilities, which are also known as terminals, and distributed that fuel to gas stations across Cook

County.

¶5 Cook County, through the Cook County Retail Sale of Gasoline and Diesel Fuel Tax

Ordinance (Ordinance) (Cook County Ordinance No. 11-O-19 (approved Feb. 16, 2011)

(codified at Cook County Code of Ordinances § 74-470 et seq. (approved Feb. 16, 2011))),

imposes a tax of six cents per gallon on the retail sale of gasoline or diesel fuel in Cook County.

While the tax is designed to ultimately be imposed upon the consumer, the distributor collects

the tax from the retail dealer 1 upon delivery. The distributor then remits that payment to the

Department. The retail dealer is compensated when the fuel is sold to the consumer by including

the six-cents-fuel per gallon tax to the fuel cost. If a distributor does not collect the tax from a

retail dealer, the retail detailer is required to remit payment to the Department “within 30 days

of the receipt of such gasoline or diesel fuel.”

Retail dealer means “any person who engages in the business of selling gasoline, diesel fuel, 1

biodiesel fuel, or gdiesel fuel in the County to a purchaser for use or consumption and not for resale in any form.” Cook County Code of Ordinances § 74-471 (approved Feb. 16, 2011).

-3- No. 1-22-0056

¶6 Buchanan North did not dispute the aforementioned process and claimed that it followed

the process to the best of its understanding and guidance. Buchanan North argued that—though

Buchanan North, Buchanan South, and Buck’s were separate legal entities—they were part of a

“unitary-business structure.” As a result, when Buck’s picked up fuel from Buchanan North’s

terminal, no fuel tax was paid. When the fuel was delivered by Buck’s to a gas station owned by

Buchanan North or Buchan South, no fuel tax was collected. Buchanan North collected the fuel

tax on the retail level from the Buchanan North and Buchanan South gas stations and remitted

the tax to the Department. By contrast, when Buck’s delivered fuel to other gas stations in Cook

County, Buchanan North, as a distributor, collected the fuel tax from these gas stations as part

of the sale of fuel to them.

¶7 The Department, in its audit, determined that Buchanan North should have collected the

fuel tax on all gasoline and diesel fuel delivered to Cook County gas stations owned by Buchanan

North or Buchanan South at the time of delivery. Buchanan North stated that Buchanan South

and Buchanan North gas stations did not pay for fuel deliveries because they are part of the same

business entity. 2 The Department required distributors to remit the fuel tax using tax forms

created by the Department, and the instructions accompanying the tax forms required distributors

to enter beginning and ending fuel inventories of fuel. There was no indication that the

Department told Buchanan North that terminals were expected to document beginning and

ending fuel inventories, but distributors were not. This distinction was not published and was

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2024 IL App (1st) 220056, 251 N.E.3d 463, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buchanan-energy-n-llc-v-county-of-cook-illappct-2024.