In re Application of Skidmore

Summary

The Illinois Appellate Court, Second District, affirmed the circuit court’s order directing issuance of a tax deed. The court held that using the property index number as the certificate-of-sale number on statutory tax-sale notices constituted strict compliance with the Illinois Property Tax Code because the notices contained complete and correct information.

Holdings

1. Although the appellant failed to provide a complete record of the trial proceedings, the record was sufficient to resolve the statutory-construction question presented; any doubts or deficiencies in the record were construed against the appellant.
2. A tax-sale purchaser strictly complies with the Illinois Property Tax Code when the required post-sale and subsequent notices contain complete and correct information, including the use of the property's PIN as the certificate-of-sale number where the county clerk does not issue a separate certificate number.

Questions Presented

1. Whether using the property's PIN as the certificate-of-sale number on the required tax-sale notices strictly complied with the Illinois Property Tax Code.
2. Whether the incomplete record required presumptions against the appellant regarding alleged findings made by the circuit court.

Disposition

affirmed