ArticlesVol. 6, No. 2

Who Wins Residential Property Tax Appeals?

Randall K. Johnson

Assistant Professor of Law, Mississippi College School of Law
Citation:6 Colum. J. Tax L. 209

Abstract

This article explains who wins residential property tax appeals in Cook County, Illinois. It does so by collecting and combining public sector data, which has been recently released by the Cook County Assessor. The article then uses this data to compute three statistics. Lastly, it contextualizes each statistic in order to determine if some townships, or groups of townships, win more appeals than expected.

I. Introduction

Serious budgetary shortfalls have plagued state and local governments for a number of years.[1] Traditionally, budgetary shortfalls arose from government failures such as excessive spending, optimistic projections, and modest tax collections.[2] These shortfalls often were made worse by other market failures.[3] An example of a case in point was provided by the Great Recession.

The Great Recession, which “started in 2007 [and] . . . caused the largest collapse in state [tax] . . . revenues on record,”[4] forced many governments to set new budgetary priorities. Some governments, in response, reduced spending to eliminate budgetary shortfalls.[5] Other states focused their efforts on increasing public sector efficiency.[6] A third category emphasized improving tax collections.[7]

Improving tax collections may be the single best approach, since it is one of the few “options available . . . outside of the . . . ‘either-or’ framework of tax increases and spending cuts.”[8] This approach also works well due to a relative lack of visibility.[9] Lastly, it may help to eliminate unjustified grants of relief.[10]

Using a newly released dataset from the second-largest county in the U.S.[11]—Cook County, Illinois—my article describes one way to improve local tax collections. It does so by critically assessing the residential property tax appeals process in Cook County, which has led to about $345 million in property valuation reductions during a recent tax year.[12] As a result, this article explains why more governments should eliminate unjustified property tax appeals.

In carrying out its work, this article draws on recent tax law scholarship. It is informed, for example, by cutting-edge behavioral law and economics research.[13] The article also builds on interdisciplinary studies that ask if property tax appeals impact local tax burdens.[14] A third influence is work that explores the relationship between property tax appeals and inequality.[15]

Within this context, the article makes three contributions to the property tax appeal literature.[16] First, it identifies the township location of every residential property that is taxed in Cook County. Next, this article identifies the township location of every residential property tax appeal that is filed between 2009 and 2013. Finally, it combines and analyzes this data, thereby determining if some townships, or groups of townships, “win” more appeals than anticipated.[17]

The article proceeds in five additional parts. Part II describes the applicable law in Cook County. Part III explains this article’s methodological approach. Part IV outlines its preliminary research findings. Part V contains the article’s normative recommendations. Part VI is the conclusion.

II. Applicable Law

In Illinois, the property tax is the largest source of state tax revenues.[18] This tax, on average, yields $59,466,000 in annual revenues.[19] About half of these revenues are collected in Cook County,[20] which is the second-largest property tax assessment area in the entire U.S.[21] These revenues have grown markedly over time, especially during the last 25 years.[22]

Under applicable law, Cook County uses a real property classification system to make tax assessments.[23] This classification system recognizes seven property types: vacant land (Class-1), residential properties (Class-2), apartments (Class-3), nonprofits (Class-4), commercial properties (Class-5A), industrial properties (Class-5B), and various properties (Class-Incentives).[24] The tax rate is ten percent for vacant land, residential properties, apartments, and various properties, whereas it is 25 percent for nonprofit properties, commercial properties, and industrial properties.[25] These tax rates became fully effective in Tax Year 2011.[26]

The classification system also “establishes a requirement of uniformity of assessments [so as to assure that] . . . the assessing authority [assigns an accurate] . . . value for real property.”[27] This requirement does not “call for mathematical equality . . . A practical uniformity, rather than an absolute one, is the test.”[28] This uniformity test has been challenged in a variety of ways.[29]

A less controversial practice, as indicated by the modest amount of litigation that it generates over time, is the real property tax appeal process.[30] Under this process,[31] which begins with the Cook County Assessor or with the Cook County Board of Review,[32] “property owners within a township may appeal their assessment every year . . . , as long as the appeal is filed within the period of time [that] their township is ‘open.’”[33] Property owners may learn about township openings opening by mail,[34] as well as through publication in a general circulation newspaper.[35]

To successfully appeal an assessment, property owners must produce legally-sufficient evidence.[36] This evidence may show that there is an error in the property description, a lack of uniformity, or a mistake in the property valuation.[37] All evidence must be filed as part of a property tax appeal complaint.[38]

Once an appeal is submitted, and decided, the property owner is notified by mail.[39] This final decision may be appealed, as of right.[40] Additional options for appeal, beyond a reconsideration or a re-review, also could be available.[41] These options include a review by the Illinois Property Tax Appeals Board or an appeal to the Circuit Court of Cook County.[42]

III. Methodology

My article introduces a new property tax appeal dataset for Cook County, which counsels for the elimination of unjustified property tax appeals. It does so, initially, by collecting and combining public sector data.[43] Then, these data are used to compute three statistics: the percentage of residential properties that appeal their assessments, the percentage of successful appeals, and the percentage of successful appeals with an attorney.[44] Lastly, the article contextualizes these statistics: in order to determine whether some townships, or groups of townships, win more residential property tax appeals than expected.[45]

This project is undertaken, in the first instance, at the aggregate-level (i.e. Cook County).[46] Next, it is undertaken at the group level (i.e. the 13 townships that are located in the Northwest Suburbs, the 17 townships that are located in the Southwest Suburbs, and the eight townships that are located in the City of Chicago).[47]  The project, finally, is undertaken at the individual level (i.e. each of the 38 townships that are used for tax purposes).[48]  In the process, this article explains which townships win the most residential property tax appeals.[49]

A single methodological approach is used, percentage analysis.[50] This approach “consists of reducing a series of related amounts to a series of percentages of a given base.”[51] Depending on the characteristics of these related amounts, the unit of analysis is a “percentage” or a “rate.”

Percentage analysis is used for at least three reasons. First, the approach is “helpful in evaluating the relative size of items or the relative change in items.”[52] Percentage analysis also provides “a useful way of comparing fractions with different denominators.”[53] Lastly, the approach lays “a solid foundation for discussing . . . more complicated . . . [empirical] issues.”[54]

This approach, however, will not be useful if the article does not account for a range of methodological issues. Several methodological issues are dealt with deliberately by this article. For example, selection effects are accounted for by testing all 38 townships in Cook County. Omitted variables are dealt with by testing these townships at the aggregate, group, and individual levels. Additional problems have been avoided by identifying who wins residential property tax appeals.

IV. Findings

This article collects data about the 1,532,170 taxable properties in Cook County.[55] It later combines the data with other information, which focuses on the 484,956 residential property tax appeals that were filed over the last 5 years.[56] Finally, the article analyzes the combined data to determine if some townships, or groups of townships, win more than expected. The article’s computations, and its research findings, are summarized in Sub-Parts A, B, and C.

A. Northwest Suburbs

The thirteen townships in the Northwest Suburbs, at least when compared to the entire population of Cook County townships, win more residential property tax appeals than expected.[57] For example, 7.2 percent of all Northwest Suburban residences appealed their tax assessment (versus 6.3 percent of all Cook County residences).[58] Of this subset of Class-2 properties, 3.7 percent then went on to successfully appeal (as opposed to 3 percent of the sample population).[59] Finally, 1.8 percent of all Northwest Suburban residences successfully appealed with an attorney (versus 1.3 percent of all Cook County residences).[60]

B. Southwest Suburbs

The 17 townships in the Southwest Suburbs, at least when compared to the entire population of Cook County townships, win more residential property tax appeals than expected.[61] For example, 8 percent of all Southwest Suburban residences appealed their tax assessment (versus 6.3 percent of all Cook County residences).[62] Of this sub-set of Class-2 properties, 4 percent also went on to successfully appeal (as opposed to 3 percent of the sample population).[63] Lastly, 1.4 percent of all Southwest Suburban residences successfully appealed using an attorney (versus 1.3 percent of all Cook County residences).[64]

C. City of Chicago

The eight townships within the City of Chicago, at least when compared to the entire population of Cook County townships, win less residential property tax appeals than expected.[65] For example, 4.8 percent of all City of Chicago residences appealed their tax assessment (versus 6.3 percent of all Cook County residences).[66] Of this sub-set of Class-2 properties, then, 2.1 percent went on to successfully appeal (as opposed to 3 percent of the sample population).[67] Finally, 1 percent of all City of Chicago residences successfully appealed with an attorney (versus 1.3 percent of all Cook County residences).[68]

V. Discussion

The article finds that Northwest and Southwest Suburban townships win more tax appeals than anticipated, in absolute and relative terms.[69] The finding remains true whether wins are defined in terms of the percentage of residential properties that appeal their tax assessments, the percentage of residential properties that successfully appeal, or the percentage of residential properties that successfully appeal with an attorney. This finding, however, is expressly limited to the last five tax years.

This finding carries positive and normative implications for Cook County. Among the positive implications is that Cook County residents cannot claim, at least with respect to residential property tax appeals, that suburban townships are treated more poorly than urban townships. More research, however, is needed[70] to confirm or disprove related claims.[71]

The normative implications, in comparison, are somewhat less obvious. For example, Cook County could point out that appeals are very costly.[72] It also may limit current public outreach efforts, at least to the 30 suburban townships, so as to discourage unjustified property tax appeals.[73] Lastly, Cook County could standardize its property tax appeal requirements.[74]

Cook County should take up each recommendation for three reasons. First, these reforms may limit moral hazard.[75] Next, each recommendation could ensure that the property tax remains horizontally and vertically equitable.[76] Lastly, these reforms may help to deter future litigation.[77]

It must be recognized, however, that special interest groups could oppose these recommendations.[78] This potential opposition may be overcome in several ways. For example, Cook County could show that most residential properties are significantly under-assessed.[79] It may also point out that “the proportions of property owners appealing . . . assessments . . . are relatively high.”[80] Lastly, Cook County could explain the problem with unjustified property tax appeals.[81]

VI. Conclusion

This article finds that suburban townships win more residential property tax appeals than anticipated.[82] The finding remains true whether wins are defined in terms of residential property tax appeal percentages, successful appeal percentages or successful appeal percentages with an attorney.[83] This conclusion is based, initially, on the fact that Northwest Suburban townships win more than expected.[84] It is also supported by a finding that Southwest Suburban townships win more than anticipated.[85] Finally, the conclusion is substantiated by a third result: City of Chicago townships win less than expected.[86] As a result, this article explains who wins residential property tax appeals.

Appendix

Table 1: Residential Property Tax Appeals: Cook County, Illinois

TOWNSHIP[87] (Tax Code)[88] 2009[89] 2010[90] 2011[91]  2012[92] 2013[93] 2009-2013 AVERAGE
BARRINGTON*(100, 101) 521 1331 419 572 710 711
BERWYN(110) 664 267 1654 684 1658 985
BLOOM(120, 121, 122) 938 554 2329 796 2483 1420
BREMEN(130, 131) 1113 466 3314 1316 3877 2017
CALUMET(140) 157 60 568 156 618 312
CICERO(150) 684 438 1553 801 1253 946
ELK GROVE*(160, 161, 164) 1341 2370 635 1042 1495 1377
EVANSTON*(170) 1369 2995 838 1057 1295 1511
HANOVER*(180, 181) 2089 3015 1713 1196 1750 1953
LEMONT(190) 846 471 1645 646 1663 1054
LEYDEN*(200, 201, 202, 204) 1999 4514 999 2374 3090 2595
LYONS(210, 211, 212, 214) 2772 1306 6369 2228 6788 3893
MAINE*(220, 221, 222) 2357 6083 1317 1776 3048 2916
NEW TRIER*(230, 234) 3004 6112 1426 1605 2488 2927
NILES*(240, 244) 1846 4293 2241 2031 2534 2589
NORTHFIELD*(250, 251, 252) 2841 7101 1422 1588 2402 3071
NORWOOD PARK*(260) 397 1188 413 619 704 664
OAK PARK(270) 962 459 3443 1283 3981 2026
ORLAND(280) 2048 1299 5093 1690 5002 3026
PALATINE*(290, 291) 2528 5776 1354 1590 2568 2763
PALOS(300) 1009 342 3103 890 3222 1713
PROVISO(310, 311, 314) 2514 1737 5592 2396 6227 3693
RICH(320, 321, 324) 1347 419 3351 1320 3776 2043
RIVER FOREST(330) 262 184 1320 520 1332 724
RIVERSIDE(340) 229 211 1324 660 1251 735
SCHAUMBURG*(350) 2621 6130 1708 1207 1706 2674
STICKNEY(360, 361) 667 167 1334 508 1532 842
THORNTON(370, 371, 372) 2322 1755 5391 1813 4898 3236
WHEELING*(380, 381, 382) 2889 6299 1540 2422 2965 3223
WORTH(390, 391) 3784 3955 6710 4381 6582 5082
HYDE PARK^(700) 4876 1833 1920 5261 1939 3166
JEFFERSON^(710, 711) 12694 4251 5023 19452 6572 9598
LAKE^(720, 721) 7619 3191 1770 7948 2325 4571
LAKE VIEW^(730) 10598 1858 2276 9583 2862 5435
NORTH CHICAGO^(740) 3449 1419 932 3399 885 2017
ROGERS PARK^(750) 2393 530 635 2390 784 1346
SOUTH CHICAGO^(760, 765) 3376 1476 818 3071 961 1940
WEST CHICAGO^(770) 9342 4291 2984 10667 3703 6197
COOK COUNTY TOTALS 102467 90146 86476 102938 102929 96991

Table 2: Successful Residential Property Tax Appeals: Cook County, Illinois

TOWNSHIP[94] (Tax Code)[95] 2009[96] 2010[97] 2011[98]  2012[99] 2013[100] 2009-13 AVERAGE
BARRINGTON*(100, 101) 217 554 261 297 465 359
BERWYN(110) 163 55 790 256 938 440
BLOOM(120, 121, 122) 233 320 975 367 1720 723
BREMEN(130, 131) 254 136 1509 553 1602 811
CALUMET(140) 44 28 214 55 409 150
CICERO(150) 228 128 700 281 509 369
ELK GROVE*(160, 161, 164) 431 1654 396 481 667 726
EVANSTON*(170) 322 967 406 503 582 556
HANOVER*(180, 181) 146 1788 1202 628 1085 970
LEMONT(190) 280 269 882 281 1341 611
LEYDEN*(200, 201, 202, 204) 561 3006 366 1026 2231 1438
LYONS(210, 211, 212, 214) 863 645 3132 930 4958 2106
MAINE*(220, 221, 222) 766 2022 629 816 1249 1096
NEW TRIER*(230, 234) 448 4553 829 828 1555 1643
NILES*(240, 244) 496 1228 1038 1056 1686 1101
NORTHFIELD*(250, 251, 252) 350 4780 775 774 1535 1643
NORWOOD PARK*(260) 132 315 228 289 270 247
OAK PARK(270) 310 189 1967 587 2680 1147
ORLAND(280) 587 989 2513 948 3758 1759
PALATINE*(290, 291) 894 3963 699 745 1829 1626
PALOS(300) 262 116 1513 390 2376 931
PROVISO(310, 311, 314) 540 1203 2262 886 4092 1797
RICH(320, 321, 324) 402 158 1433 485 2605 1017
RIVER FOREST(330) 82 61 758 189 622 342
RIVERSIDE(340) 70 95 815 342 649 394
SCHAUMBURG*(350) 262 4182 715 596 1139 1379
STICKNEY(360, 361) 186 69 498 194 1082 406
THORNTON(370, 371, 372) 459 720 2092 651 3127 1410
WHEELING*(380, 381, 382) 921 4654 766 1192 2030 1913
WORTH(390, 391) 794 2446 2612 1907 3840 2320
HYDE PARK^(700) 1389 1061 1016 2267 1224 1391
JEFFERSON^(710, 711) 3595 2932 2474 10872 4392 4853
LAKE^(720, 721) 1801 1828 618 3019 961 1645
LAKE VIEW^(730) 2934 634 1145 4478 1005 2039
NORTH CHICAGO^(740) 905 798 444 1652 452 850
ROGERS PARK^(750) 619 173 361 1230 348 546
SOUTH CHICAGO^(760, 765) 823 735 301 1353 466 736
WEST CHICAGO^(770) 2810 2377 1163 4536 2176 2612
COOK COUNTY TOTALS 26579 51831 40497 47940 63655  46100

Table 3: Successful Residential Property Tax Appeals With Attorney: Cook County, Illinois

TOWNSHIP[101] (Tax Code)[102] 2009[103] 2010[104] 2011[105]  2012[106] 2013[107] 2009-2013 AVERAGE
BARRINGTON*(100, 101) 98 358 135 151 323 213
BERWYN(110) 26 24 185 85 440 152
BLOOM(120, 121, 122) 43 79 212 125 744 241
BREMEN(130, 131) 48 43 382 185 626 257
CALUMET(140) 8 13 28 16 89 31
CICERO(150) 26 81 96 37 168 82
ELK GROVE*(160, 161, 164) 142 984 125 131 244 325
EVANSTON*(170) 103 568 166 223 332 278
HANOVER*(180, 181) 18 813 280 162 422 339
LEMONT(190) 130 137 348 79 682 275
LEYDEN*(200, 201, 202, 204) 161 1717 77 173 521 530
LYONS(210, 211, 212, 214) 215 276 1325 376 2719 982
MAINE*(220, 221, 222) 357 1308 258 326 553 560
NEW TRIER*(230, 234) 193 3473 535 524 1264 1198
NILES*(240, 244) 177 700 360 426 994 531
NORTHFIELD*(250, 251, 252) 123 3045 420 391 1128 1021
NORWOOD PARK*(260) 33 191 100 78 109 102
OAK PARK(270) 56 114 688 247 1226 466
ORLAND(280) 115 155 826 285 1960 668
PALATINE*(290, 291) 350 2269 233 189 788 766
PALOS(300) 48 39 506 188 1084 373
PROVISO(310, 311, 314) 131 316 583 222 1646 580
RICH(320, 321, 324) 134 40 282 119 805 276
RIVER FOREST(330) 33 21 402 77 372 181
RIVERSIDE(340) 19 50 287 66 294 143
SCHAUMBURG*(350) 42 1409 156 133 526 453
STICKNEY(360, 361) 37 15 108 56 383 120
THORNTON(370, 371, 372) 57 160 480 161 1056 383
WHEELING*(380, 381, 382) 217 2286 286 381 1047 843
WORTH(390, 391) 215 202 686 350 1286 548
HYDE PARK^(700) 426 379 353 978 777 583
JEFFERSON^(710, 711) 1617 950 682 4147 1748 1829
LAKE^(720, 721) 396 385 115 1028 495 484
LAKE VIEW^(730) 1774 431 740 3195 663 1361
NORTH CHICAGO^(740) 693 586 351 1272 414 663
ROGERS PARK^(750) 295 96 176 714 190 294
SOUTH CHICAGO^(760, 765) 300 270 120 589 261 308
WEST CHICAGO^(770) 1350 940 525 2451 1389 1331
COOK COUNTY TOTALS 10206 24923 13617 20336 29768  19770

Table 4: Baseline Years And Population Averages: Cook County, Illinois

TOWNSHIP[108](Tax Code)[109]     Residential Properties Subject to Taxation (Baseline Tax Year is 2009)[110] Residential Properties that Appeal their Taxes Per Year(2009-2013 Average)[111] Successful Residential Property Tax Appeals Per Year(2009-2013 Average)[112] Successful Residential Property Tax Appeals With     Attorney Per Year(2009-2013 Average)[113]
BARRINGTON*(100, 101) 5540 711 359 213
BERWYN(110) 13744 985 440 152
BLOOM(120, 121, 122) 28810 1420 723 241
BREMEN(130, 131) 38799 2017 811 257
CALUMET(140) 5124 312 150 31
CICERO(150) 13996 946 369 82
ELK GROVE*(160, 161, 164) 29276 1377 726 325
EVANSTON*(170) 21587 1511 556 278
HANOVER*(180, 181) 30790 1953 970 339
LEMONT(190) 6991 1054 611 275
LEYDEN*(200, 201, 202, 204) 28292 2595 1438 530
LYONS(210, 211, 212, 214) 35921 3893 2106 982
MAINE*(220, 221, 222) 47264 2916 1096 560
NEW TRIER*(230, 234) 20006 2927 1643 1198
NILES*(240, 244) 40046 2589 1101 531
NORTHFIELD*(250, 251, 252) 31399 3071 1643 1021
NORWOOD PARK*(260) 9035 664 247 102
OAK PARK(270) 16884 2026 1147 466
ORLAND(280) 36246 3026 1759 668
PALATINE*(290, 291) 39156 2763 1626 766
PALOS(300) 19811 1713 931 373
PROVISO(310, 311, 314) 45882 3693 1797 580
RICH(320, 321, 324) 25769 2043 1017 276
RIVER FOREST(330) 4071 724 342 181
RIVERSIDE(340) 5665 735 394 143
SCHAUMBURG*(350) 43880 2674 1379 453
STICKNEY(360, 361) 12776 842 406 120
THORNTON(370, 371, 372) 56818 3236 1410 383
WHEELING*(380, 381, 382) 55041 3223 1913 843
WORTH(390, 391) 55812 5082 2320 548
HYDE PARK^(700) 81202 3166 1391 583
JEFFERSON^(710, 711) 136660 9598 4853 1829
LAKE^(720, 721) 149742 4571 1645 484
LAKE VIEW^(730) 90280 5435 2039 1361
NORTH CHICAGO^(740) 68847 2017 850 663
ROGERS PARK^(750) 20815 1346 546 294
SOUTH CHICAGO^(760, 765) 54108 1940 736 308
WEST CHICAGO^(770) 106085 6197 2612 1331
COOK COUNTY AVERAGE  40320 2552 1213 520

Table 5: Appeal Percentages And Successful Appeal Percentages: Cook County, Illinois

TOWNSHIP[114] (Tax Code)[115]    Percentage of Residential Properties that Appeal their Taxes (2009-2013)[116] Percentage of Successful Residential Property Tax Appeals (2009-2013)[117] Percentage of Successful Residential Property Tax Appeals With Attorney (2009-2013)[118]
BARRINGTON*(100, 101) 0.128 0.065 0.038
BERWYN(110) 0.072 0.032 0.011
BLOOM(120, 121, 122) 0.049 0.025 0.008
BREMEN(130, 131) 0.052 0.021 0.007
CALUMET(140) 0.061 0.029 0.006
CICERO(150) 0.068 0.026 0.006
ELK GROVE*(160, 161, 164) 0.047 0.025 0.011
EVANSTON*(170) 0.070 0.026 0.013
HANOVER*(180, 181) 0.063 0.031 0.011
LEMONT(190) 0.151 0.087 0.039
LEYDEN*(200, 201, 202, 204) 0.092 0.051 0.019
LYONS(210, 211, 212, 214) 0.108 0.059 0.027
MAINE*(220, 221, 222) 0.062 0.023 0.012
NEW TRIER*(230, 234) 0.146 0.082 0.060
NILES*(240, 244) 0.065 0.027 0.013
NORTHFIELD*(250, 251, 252) 0.098 0.052 0.033
NORWOOD PARK*(260) 0.074 0.027 0.011
OAK PARK(270) 0.120 0.068 0.028
ORLAND(280) 0.083 0.049 0.018
PALATINE*(290, 291) 0.071 0.042 0.020
PALOS(300) 0.086 0.047 0.019
PROVISO(310, 311, 314) 0.080 0.039 0.013
RICH(320, 321, 324) 0.079 0.039 0.011
RIVER FOREST(330) 0.178 0.084 0.044
RIVERSIDE(340) 0.130 0.070 0.025
SCHAUMBURG*(350) 0.061 0.031 0.010
STICKNEY(360, 361) 0.066 0.032 0.009
THORNTON(370, 371, 372) 0.057 0.025 0.007
WHEELING*(380, 381, 382) 0.059 0.035 0.015
WORTH(390, 391) 0.091 0.042 0.010
HYDE PARK^(700) 0.039 0.017 0.007
JEFFERSON^(710, 711) 0.070 0.036 0.013
LAKE^(720, 721) 0.031 0.011 0.003
LAKE VIEW^(730) 0.060 0.023 0.015
NORTH CHICAGO^(740) 0.029 0.012 0.010
ROGERS PARK^(750) 0.065 0.026 0.014
SOUTH CHICAGO^(760, 765) 0.036 0.014 0.006
WEST CHICAGO^(770) 0.058 0.025 0.013
COOK COUNTY AVERAGE 0.063 0.030 0.013

Table 6: Appeal Percentages & Successful Appeal Percentages: Northwest Suburbs

TOWNSHIP[119] (Tax Code)[120]      Percentage of Residential Properties that Appeal their Taxes(FY 2009-2013 Average)[121] Percentage of Successful Residential Property Tax Appeals(FY 2009-2013 Average)[122] Percentage of Successful Residential Property Tax Appeals With Attorney(FY 2009-2013 Average)[123]
BARRINGTON*(100, 101) 0.128 0.065 0.038
ELK GROVE*(160, 161, 164) 0.047 0.025 0.011
EVANSTON*(170) 0.070 0.026 0.013
HANOVER*(180, 181) 0.063 0.031 0.011
LEYDEN*(200, 201, 202, 204) 0.092 0.051 0.019
MAINE*(220, 221, 222) 0.062 0.023 0.012
NEW TRIER*(230, 234) 0.146 0.082 0.060
NILES*(240, 244) 0.065 0.027 0.013
NORTHFIELD*(250, 251, 252) 0.098 0.052 0.033
NORWOOD PARK*(260) 0.074 0.027 0.011
PALATINE*(290, 291) 0.071 0.042 0.020
SCHAUMBURG*(350) 0.061 0.031 0.010
WHEELING*(380, 381, 382) 0.059                0.035 0.015
NORTHWEST SUBURBS* (13 TOWNSHIPS) 0.072 0.037 0.018
COOK COUNTY(38 TOWNSHIPS) 0.063 0.030 0.013

Table 7: Appeal Percentages & Successful Appeal Percentages: Southwest Suburbs

TOWNSHIP[124] (Tax Code)[125]      Percentage of Residential Properties that Appeal their Taxes(FY 2009-2013 Average)[126] Percentage of Successful Residential Property Tax Appeals(FY 2009-2013 Average)[127] Percentage of Successful Residential Property Tax Appeals With Attorney(FY 2009-2013 Average)[128]
BERWYN(110) 0.072 0.032 0.011
BLOOM(120, 121, 122) 0.049 0.025 0.008
BREMEN(130, 131) 0.052 0.021 0.007
CALUMET(140) 0.061 0.029 0.006
CICERO(150) 0.068 0.026 0.006
LEMONT(190) 0.151 0.087 0.039
LYONS(210, 211, 212, 214) 0.108 0.059 0.027
OAK PARK(270) 0.120 0.068 0.028
ORLAND(280) 0.083 0.049 0.018
PALOS(300) 0.086 0.047 0.019
PROVISO(310, 311, 314) 0.080 0.039 0.013
RICH(320, 321, 324) 0.079 0.039 0.011
RIVER FOREST(330) 0.178 0.084 0.044
RIVERSIDE(340) 0.130 0.070 0.025
STICKNEY(360, 361) 0.066 0.032 0.009
THORNTON(370, 371, 372) 0.057 0.025 0.007
WORTH(390, 391) 0.091 0.042 0.010
SOUTHWEST SUBURBS (17 TOWNSHIPS) 0.080 0.040 0.014
COOK COUNTY(38 TOWNSHIPS) 0.063 0.030 0.013

Table 8: Appeal Percentages & Successful Appeal Percentages: City Of Chicago

TOWNSHIP[129] (Tax Code)[130]      Percentage of Residential Properties that Appeal their Taxes(FY 2009-2013 Average)[131] Percentage of Successful Residential Property Tax Appeals(FY 2009-2013 Average)[132] Percentage of Successful Residential Property Tax Appeals With Attorney(FY 2009-2013 Average)[133]
HYDE PARK^(700) 0.039 0.017 0.007
JEFFERSON^(710, 711) 0.070 0.036 0.013
LAKE^(720, 721) 0.031 0.011 0.003
LAKE VIEW^(730) 0.060 0.023 0.015
NORTH CHICAGO^(740) 0.029 0.012 0.010
ROGERS PARK^(750) 0.065 0.026 0.014
SOUTH CHICAGO^(760, 765) 0.036 0.014 0.006
WEST CHICAGO^(770) 0.058 0.025 0.013
CITY OF CHICAGO^ (8 TOWNSHIPS) 0.048 0.021 0.010
COOK COUNTY(38 TOWNSHIPS) 0.063 0.030 0.013

Acknowledgements: Special thanks to the MC Law Publications Grant Program, Dean Wendy B. Scott, Professor John Haskell, Professor Christoph Henkel, Professor Angela Kupenda, Professor Jonathan Will, Professor Amos N. Jones, Ms. Jayeeta Kundu, Mr. Taimoor Aziz, Mr. Sheldon Evans, the scholar-participants in the Third Annual Local Government Law Works-In-Progress Workshop and the editors of the Columbia Journal of Tax Law. 


[1] See, e.g., Phil Oliff, Chris Mai & Vincent Palacios, States Continue to Feel Recession’s Impact, Ctr. on Budget & Pol’y Priorities (Jun. 27, 2012), http://www.cbpp.org/cms/index.cfm?fa=view&id=711 (“In the early 2000s, as in the early 1990s and early 1980s, state fiscal problems lasted for several years after the recession ended.”).

[2] See Clifford Winston, Government Failure vs. Market Failure: Microeconomics Policy Research and Government Performance, Brookings (Sept. 2006)), http://www.brookings.edu/research/papers/2006/ 09/monetarypolicy-winston (“Government failure, [which is a type of a market failure,] . . . arises when government has created inefficiencies because it should not have intervened in the first place or when it could have solved a given problem or set of problems more efficiently, that is, by generating greater net benefits.”).

[3] Public Production: Government Failure vs. Market Failure: Hearing Before the H.R. Comm. on Fin. Serv., 110th Cong. 1 (2007) (statement of Clifford Winston, Senior Fellow, Economic Studies, The Brookings Institution) (“Market failure occurs when a socially desirable good or service–that is, a good or service whose social benefits exceed its social costs–is not provided because firms would find it unprofitable to do so.”).

[4] Oliff, supra note 1, at 1.

[5] See, e.g., Iris J. Lav & Dylan Grundman, A Balanced Approach to Closing State Deficits, Ctr. on Budget & Pol’y Priorities 2 (Feb. 25, 2011), http://www.cbpp.org/cms/?fa=view&id=3084 (“[In cases where state governments are prohibited]… from running a deficit, state policymakers’ first impulse when confronting a revenue shortfall is usually to reduce spending.”).

[6] See Id. at 3 (“[For example, public expenditure] on prisons and related areas is getting a lot of attention during this recession and its aftermath; a number of states have been looking at ways to reduce corrections budgets without compromising public safety.”).

[7] See Id. at 7–8 (“After soliciting recommendations from a review panel, Iowa passed a law in 2010 that places limitations on certain business-related credits, creates a tax expenditure review committee, and requires the committee to closely evaluate each tax expenditure’s costs and benefits at least once every five years.”).

[8] Id. at 1.

[9] See Id. at 7 (“Each year states give up billions of dollars of revenue in the form of tax [exemptions–including tax assessment reductions,] credits, deductions, and exemptions spent through the tax code as opposed to through the regular appropriations process. . . . But there is an important difference . . . expenditures . . . receive far less scrutiny.”).

[10] Id. (“[Unjustified grants of relief, generally, arise because]… policymakers do not regularly examine tax expenditures, nor do states document their effectiveness the same way they do for on-budget expenditures.”).

[11] See Office of the Cook County Assessor, Cook County Residential Property Tax Assessment Data, 1993–2012 (2013) [hereinafter Assessor], which was directly provided to the author by the Office of the Cook County Assessor in Jan. 2013; see Office of the Cook County Assessor, Cook County Residential Property Tax Appeals Data, 2009–2013 (2014) [hereinafter Assessor 2], which was directly provided to the author by the Office of the Cook County Assessor in May 2014 and in Nov. 2014; see infra Tables 1, 2, 3, 4 & 5.

[12] See Civic Federation, Cook County Property Tax Appeals: A Primer on the Appeals Process with Comparative Data for 2000–2008, 15 (2009) [hereinafter Civic Federation] (“The total amount of the reductions in assessed [property] value granted by the [Cook County] . . . Assessor’s Office declined by $1.3 billion, or 38.6%, between 2000 and 2008. While the value of assessment reductions granted to residential properties increased during this time from $158.4 million to $344.6 million, the value of assessment reductions granted to all other [property types] . . . declined by $1.5 billion.”).

[13] See, e.g., Andrew T. Hayashi, The Legal Salience of Taxation, 81 U. Chi. L. Rev. 1443 (2014).

[14] See, e.g., Rachel N. Weber & Daniel P. McMillen, Ask and Ye Shall Receive? Predicting the Successful Appeal of Property Tax Assessments, 38 Pub. Fin. Rev. 74 (2010) [hereinafter Weber].

[15] See, e.g., Brent C. Smith, Intrajurisdictional Segmentation of Property Tax Burdens: Neighborhood Inequities Across an Urban Sphere, 30 J. Real Est. Res. 207 (2008).

[16] See Weber, supra note 14, at 77 (“Unfortunately, scant research has been undertaken on the topic of property tax appeals.”).

[17] In order to determine who wins residential property tax appeals, this article uses percentage analysis. This simplified approach permits the computation of three win percentages. These win percentages are computed at the aggregate level, at the group level, and at the individual township level. Within this context, any individual or group-level average that is higher than the population average indicates that there may be more wins than anticipated. In contrast, any individual or group-level average that is lower than the population average indicates that there may be less wins than expected. In cases where the averages are equal, then that individual or group wins as frequently as anticipated. This article makes no attempt to determine whether the observed differences are statistically significant, but it still may serve as a potential point of departure for future research. Cf. Randall K. Johnson, Where Schools Close In Chicago, 7 Alb. Gov’t L . Rev. 508, 51011 n.20 (2014) (“[Future] research may go beyond the basic question to be answered in this article: ‘are there [any] differences between the samples or categories of the independent variable?’ Instead, it asks: ‘are the differences between the samples large enough to reject the null hypothesis and [to] justify the conclusion that the populations represented by the samples are different?’”) (citations omitted).

[18] See Ares G. Dalianis & Scott R. Metcalf, Property Tax Litigation, Ill. Inst. for Continuing Legal Educ. 12.1 (2013) [hereinafter Dalianis].

[19] See State Tax Revenues: Charts and Data, Governing (2012), http://www.governing.com/gov-data/state-tax-revenue-data.html (displaying an interface that permits the entry of information, which identifies state property tax revenues over time, by entering: State: Illinois; Tax Type: Property Tax). In recent years, Illinois had state property tax revenues of $59,134,000 (2008); $63,853,000 (2009); $50,962,000 (2010); $58,273,000 (2011); and $65,106,000 (2012). The average annual revenue over this five-year period was $59,466,000.

[20] See 2012 Property Tax Statistics, Illinois.gov (2012), http://tax.illinois.gov/AboutIdor/ TaxStats/PropertyTaxStats/2012/index.htm; see Dalianis, supra note 18, at 12.1 (“Approximately 45 percent of all [Illinois] property taxes are collected in Cook County.”).

[21] See Weber, supra note 14, at 76.

[22] See Dalianis, supra note 18, at 12.1 (“The increase in [Illinois] . . . property taxes from 1989 to 2010 was 192.5 percent, or an annual average rate of increase of 5.24 percent.”).

[23] See Id. at 12.212.3 (“Property tax assessment litigation is governed almost exclusively by state law. The Illinois Constitution and the Property Tax Code, 35 ILCS 200/1-1, et seq., provide exceptional detail and guidance for real property taxation in Illinois. . . . [It nevertheless] should be noted that property tax litigation, particularly assessment appeals, can give rise to equal protection claims under the Fourteenth Amendment to the United States Constitution. . . . See, e.g., Allegheny Pittsburgh Coal Co. v. County Commission of Webster County, West Virginia, 488 U.S. 336, 102 L.Ed.2d 688, 109 S.Ct. 633 (1989). However, the Tax Injunction Act, 28 U.S.C. §1341, provides that ‘district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State.’ . . . The effect of the Tax Injunction Act is that almost all assessment litigation is pursued under state law.”).

[24] See Id. at 12.6 (“Article IX, § 4, of the Illinois Constitution allows counties with a population of more than 200,000 to classify real property for taxation purposes. Cook County . . . is the only county in Illinois that classifies real property for taxation purposes.”).

[25] See Id. (“The Cook County Board of Commissioners adopted significant amendments to the Cook County Real Property Assessment Classification Ordinance, Cook County Code of Ordinances §74-64, which were effective beginning in the 2009 tax year. Cook County Ordinance No. 08-0-51 (Sept. 17, 2008).”).

[26] See Id. (“For the 2011 tax year and beyond, assessments in Cook County will be either 10 percent or 25 percent of the fair cash value of the property.”).

[27] ILL. CONST. art. IX, §4(a).

[28]Apex Motor Fuel Co. v. Barrett, 169 N.E.2d 769 (Ill. App. Ct. 1960).

[29] See, e.g., Cook Cnty. Bd. of Review v. Prop. Tax Appeal Bd., 791 N.E.2d 8 (Ill. App. Ct. 2002); see, e.g., Cook Cnty. Bd. Of Review v. Prop. Tax Appeal Bd., 803 N.E.2d 55 (Ill. App. Ct. 2003).

[30] See J. Lyn Entrikin, Symposium: V. Atypical Consumer Agreements as Aberrant Contracts: Tax Ferrets, Tax Consultants, Bounty Hunters, and Hired Guns: The Property Tax Netherworld Fueled By Contingency Fees and Campertous Agreements, 89 Chi.-Kent L. Rev. 289, 296 (2014) (“Relatively few assessment appeals reach the state appellate courts.”).

[31] See 35 Ill. Comp. Stat. 200/14-35 (2014).

[32] See Robert M. Sarnoff & Michael F. Baccash, Administrative Challenges to Assessments and Equalizations, Illinois Institute for Continuing Legal Education 5.1 (2012) (“The Property Tax Code, 35 ILCS 200/1-1, et seq., provides that assessments may be revised either by the [Cook County] assessor or the [Cook County] board of review, depending on when the revision is requested.”) [hereinafter Sarnoff].

[33] Dalianis, supra note 18, at 12.8.

[34] See Id. (“The Cook County Assessor typically launches the general assessment process by sending notice to all property owners in the district being reassessed, advising them of the proposed assessment for their property. The notice of the change in assessment provides a date, generally 30 days from the date of the notice, before which the property owner may file an appeal.”); see 35 Ill. Comp. Stat. 200/14-35.

[35] See Sarnoff, supra note 32, at 5.3 (“The assessor is required to publish a schedule of the dates on which he or she will hear complaints concerning real property assessments from one or more townships or taxing districts after the assessment books are complete. Publication of schedules must occur in a newspaper of general circulation within the county at least one week before the hearings.”); see 35 Ill. Comp. Stat. 200/14-35; see Sarnoff, supra note 32, at 5.10 (“The board of review in a county with three million or more inhabitants must publish notice in a newspaper of general circulation within the county specifying the time and place at which taxpayers may file complaints.”); see 32 Ill. Comp. Stat. 200/16-110. Generally speaking, real properties are re-assessed every three years in Cook County.

[36] See Sarnoff, supra note 32, at 5.4 (“Each complaint filed with the Cook County Assessor must contain the township, volume, permanent index number, and name and address of the complainant. The taxpayer must also provide additional information pertaining to the value of the property and the basis for the complaint in accordance with the assessor’s rules.”); see Sarnoff, supra note 32, at 5.11 (“Evidence should support a taxpayer’s complaint [to the Cook County Board of Review.”).

[37] See Sarnoff, supra note 32, at 5.11 (“When using comparable sales as a basis for a complaint, a listing of the various comparable properties should include the permanent index numbers of each comparable, the date of sale, the sales price, the document number of the deed, and the unit value of the comparison (e.g. rental value per room of an apartment building.”)).

[38] See Sarnoff, supra note 32, at 5.3 (“A taxpayer may file a complaint with the Cook County Assessor before the assessor completes and verifies the assessment books. After filing a valuation complaint, the taxpayer is entitled to an opportunity to be heard in support of the complaint.”); see 35 Ill. Comp. Stat. 200/9-85; see Civic Federation, supra note 12, at 16-7 (“The methods of presenting these complaints are largely the same as at the Assessor’s office . . . . After a proper complaint is filed, the Board schedules a public hearing on the complaint.”); see 35 Ill. Comp. Stat. 200/16-95(1); see 35 Ill. Comp. Stat. 200/16‑120.

[39] See Civic Federation, supra note 12, at 5 (“The [Cook County] Assessor’s Office notifies the property taxpayer of its decision by mail.”); see Civic Federation, supra note 12 at 17 (“The taxpayer is notified by letter of the Board [of Review’s] decision regarding the assessment.”).

[40] See Civic Federation, supra note 12, at 5 (“A property taxpayer unsatisfied with the decision may request a reconsideration of the assessment by the [Cook County] Assessor’s Office.”); see Civic Federation, supra note 12, at 17 (“Once a decision is rendered, the property taxpayer may request that the Board [of Review] re-review the assessment.”).

[41] See Civic Federation, supra note 12, at 28. (“Only those parties who filed a complaint at the Board of Review may further appeal assessments at the Illinois Property Tax Appeal Board (PTAB) or the Circuit Court of Cook County.”); see 35 Ill. Comp. Stat. 200/16-180.

[42] Id.

[43] See Assessor, supra note 11; see Assessor 2, supra note 11.

[44] See infra Tables 6, 7, and 8.

[45] Id.

[46] See infra Tables 4 and 5.

[47] See infra Tables 6, 7, and 8.

[48] See infra Tables 4 and 5.

[49] See infra Tables 4, 5, 6, 7, and 8.

[50] See Financial Analysis Primer, Introduction: Basic Financial Statement Analysis, Objective Five, 2014 http://www.wiley.com/college/kieso/0471363049/dt/analysttool/faprimer/fap11.htm.

[51] Id.

[52] Id.

[53] International Centre of Excellence in Mathematics, Percentages: A Guide for Teachers – Years 7 and 8, Number and Algebra: Module 20, 1 (June 2011).

[54] Jessica Polito, The Language of Comparisons: Communicating about Percentages, 7 Numeracy 14 (2014).

[55] See Assessor, supra note 11.

[56] See Assessor 2, supra note 11.

[57] Compare infra Table 6 with infra Table 5. Northwest Suburban townships had 401,312 taxable properties in 2009, which is 26 percent of the 1,532,170 taxable properties in Cook County. In contrast, this subset of townships had 144,868 residential property tax appeals between 2009 and 2014, which is 30 percent of the 484,956 residential property tax appeals in Cook County.

[58] Id.

[59] Id.

[60] Id.

[61] Compare infra Table 7 with infra Table 5. Southwest Suburban townships had 423,119 taxable properties in 2009, which is 28 percent of the 1,532,170 taxable properties in Cook County. In contrast, this subset of townships had 168,732 residential property tax appeals between 2009 and 2014, which is 35 percent of the 484,956 residential property tax appeals in Cook County.

[62] Id.

[63] Id.

[64] Id.

[65] Compare infra Table 8 with infra Table 5. City of Chicago townships had 707,739 taxable properties in 2009, which is 46 percent of the 1,532,170 taxable properties in Cook County. In contrast, this subset of townships had 171,356 residential property tax appeals between 2009 and 2014, which is 35 percent of the 484,956 residential property tax appeals in Cook County.

[66] Id.

[67] Id.

[68] Id.

[69] Compare infra Table 6 with infra Table 5 (Northwest Suburban townships wins more than expected in absolute terms); compare infra Table 7 with infra Table 5 (Southwest Suburban townships win more than anticipated in absolute terms); compare infra Table 6 with infra Table 8 (Northwest Suburban townships win more than City of Chicago townships in relative terms); compare infra Table 7 with infra Table 8 (Southwest Suburban townships win more than City of Chicago townships in relative terms). The reason why suburban townships win more often is outside the scope of this article. The author plans to answer this question, among others, in a future publication.

[70] Cf., e.g., Randall K. Johnson, Why We Need A Comprehensive Recording Fraud Registry, 2014 N.Y.U. J. Legis. & Pub. Pol’y Quorum 88, 90 (2014); Randall K. Johnson, Why Police Learn From Third-Party Data, 3 Wake Forest L. Rev. Online 1, 4 (2013); Randall K. Johnson, Do Police Learn From Lawsuit Data?, 40 Rutgers L. Rec. 30, 37–38 (2012–2013).

[71] Compare E.J. Dionne, How Government Helps the 1 Percent, Wash. Post (Jan. 14, 2015), http://www.washingtonpost.com/opinions/ej-dionne-how-government-helps-the-1-percent/2015/01/14/ 17cf8448-9c29-11e4-a7ee-526210d665b4_story.html with Greg Hinz, Chicago Homeowners Get Tax Break Relative to Burbs, Crain’s Chicago Business (Dec. 12, 2013), http://www.chicagobusiness.com/article/ 20131212/BLOGS02/131219903/chicago-homeowners-get-tax-break-relative-to-burbs.

[72] See Weber, supra note 14, at 75 (“[Residential property tax appeal] . . . processes are . . . expensive to administer, as adjudicators must devote scarce resources and staff time to distinguish between frivolous and legitimate claims.”).

[73] Id. at 81 (“Since 1998, the Cook County Assessor and several alderman and county commissioners have made concerted efforts to solicit appeal from residential property owners—for example, staffing satellite offices at grocery stores and senior centers and investing heavily in publicity materials that made the process more accessible and transparent.”).

[74] This recommendation would have the added benefit of bringing the appeals process that is used by the Office of the Cook County Assessor into complete alignment with the appeals process that is used by the Cook County Board of Review.

[75] See Stewart E. Sterk and Mitchell L. Engler, Property Tax Reassessment: Who Needs It, 81 Notre Dame L. Rev. 1037, 1039–40 (2006) (“[Moral hazard often arises when] a taxpayer whose tax assessment is low relative to the benefits she receives from additional municipal services [consumes] . . . additional services even when the costs of those services greatly exceed their benefit.”).

[76] See Weber, supra note 14, at 75 (“Appeals could make property tax assessments less uniform and violate the principle of horizontal equity, which assumes that two taxpayers with identical houses receive the same assessment. If only the one who appeals receives a lowered assessment, appeals can lead to disparate tax rates despite the use of a single, nominal tax rate. Appeals also could make the distribution of the property tax less vertically equitable and even ‘regressive’ if applications and successful appeals were correlated with higher-valued properties—either because owners of higher-valued homes were more likely to appeal or because assessors were more likely to grant relief to such owners.”).

[77] Cf. Roxanna Asgarian, New Property Tax Bills Would Stymie Appeals form Trophy Towers, Houston Business Journal, http://www.bizjournals.com/houston/morning_call/2015/03/new-property-tax-bills-would-stymie-appeals-from.html?page=all (March 10, 2015) (“Three new bills in the Texas legislature this year take aim at a passage in the tax code that counties are saying has sharply increased the number of lawsuits against appraisal districts in the state—and taxpayers are footing a $16.1 million bill to cover the litigation.”).

[78] Entrikin, supra note 30, at 290 (“Because property owners annually transfer substantial tax dollars to state and local governments, a financial incentive exists for opportunists to step in. Taxpayers and local governments alike are vulnerable to largely unregulated agents whose livelihoods depend on a share of the annual cash transfer of property tax dollars from property owners to local government coffers. . . . As a result, a substantial portion of the revenue that could be generated by the property tax base to finance public services is effectively diverted to private third parties to the detriment of taxpayers and local governments alike.”).

[79] Weber, supra note 14, at 81 (“In Cook County, the statutory assessment ratio for residential properties is 16 percent of market value. In practice, the average assessment ratio is closer to 9 percent.”).

[80] Id. at 83.

[81] Id. at 75 (“[For example, it could explain that when a residential property tax appeals] . . . system is systematically weighted toward certain property owners, then an adjudicator’s willingness to grant relief could alter the incidence of property tax; i.e. by lowering the burden on some property owners, it raises the burden on others.”).

[82] Compare infra Table 6 with infra Table 5; compare infra Table 7 with infra Table 5; compare infra Table 8 with infra Table 5.

[83] Id.

[84] Compare infra Table 6 with infra Table 5.

[85] Compare infra Table 7 with infra Table 5.

[86] Compare infra Table 8 with infra Table 5.

[87] See Dalianis, supra note 18, at 12.8 (“The county is divided into three assessment districts: (1) the City of Chicago; (2) that portion of the county outside of the City of Chicago and north of Illinois Route 64 (North Avenue); and (3) that portion of the county outside of the City of Chicago and south of Illinois Route 64 (North Avenue). 35 ILCS 200/9-220.”).

[88] See Office of the Cook County Clerk, Tax Code Rate Summary 1-158 (July 6, 2012) [hereinafter Clerk].

[89] See Assessor, supra note 11.

[90] Id.

[91] Id.

[92] Id.

[93] Id.

[94] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[95] See Clerk, supra note 88.

[96] See Assessor, supra note 11.

[97] Id.

[98] Id.

[99] Id.

[100] Id.

[101] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[102] See Clerk, supra note 88.

[103] See Assessor, supra note 11.

[104] Id.

[105] Id.

[106] Id.

[107] Id.

[108] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[109] See Clerk, supra note 88.

[110] See Assessor 2, supra note 11. The author used 2009 as the Baseline Tax Year, since it was the last time that all 38 townships were re-assessed in the same Tax Year.

[111] See Assessor, supra note 11.

[112] Id.

[113] Id.

[114] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[115] See Clerk, supra note 88.

[116] See Assessor, supra note 11; see Assessor 2, supra note 11. The author computed this percentage by dividing the number of residential properties that appealed their taxes, on average (Tax Years are 2009-2013), by the number of taxable properties (Baseline Tax Year is 2009).

[117] Id. The author computed this percentage by dividing the number of residential properties that successfully appealed their taxes, on average (Tax Years are 2009-2013), by the number of taxable properties (Baseline Tax Year is 2009).

[118] Id. The author computed this percentage by dividing the number of residential properties that successfully appealed their taxes using an attorney, on average (Tax Years are 2009-2013), by the number of taxable properties (Baseline Tax Year is 2009).

[119] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[120] See Clerk, supra note 88.

[121] See Assessor, supra note 11; see Assessor 2, supra note 11.

[122] Id.

[123] Id.

[124] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[125] See Clerk, supra note 88.

[126] See Assessor, supra note 11; see Assessor 2, supra note 11.

[127] Id.

[128] Id.

[129] See Dalianis, supra note 18, at 12.7; see 35 ILCS 200/9-220.

[130] See Clerk, supra note 88.

[131] See Assessor, supra note 11; see Assessor 2, supra note 11.

[132] Id.

[133] Id.