Illinois Compiled Statutes
30 ILCS 230/2a.1 (2026)
Payment of money under protest to every officer, board, commission, commissioner, department, institute, arm or agency authorized to receive moneys for or on behalf of the State shall be noted by the payer as paid under protest as to each payment so made
✓ current as of May 2026
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(30 ILCS 230/2a.1)
(from Ch. 127, par. 172a)
Sec. 2a.1.
Payment of money under protest to every officer, board,
commission, commissioner, department, institute, arm or agency authorized
to receive moneys for or on behalf of the State shall be noted by the payer
as paid under protest as to each payment so made. In cases where a single
remittance is made of an amount of money in excess of that so paid under
protest, the particular amount paid under protest together with pertinent
data descriptive of the suit or suits in relation to which such payment or
payments are made and the amount allocable to each, shall be stated.
Notice of payment under protest shall be made in substantially the
following form:
(Date).....
To: (Officer, board, etc., to whom payment is made).
You will please take notice that $.... of the attached or enclosed
remittance in the amount of $.... for (Motor Fuel Tax, Retailers'
Occupation Tax, Franchise Tax, etc., as the case may be) is made under
protest.
The undersigned is an original (or intervening) party plaintiff in the
following case or cases in relation to which the aforesaid payment is made
under protest.
(Here list title of case or cases, the court in which pending, and the
general court number assigned to each. If more than one suit is pending,
the specific amount paid under protest as to each case shall be stated by
the person making payment under protest.)
....
(Name of person making payment under protest.)
....(Address)
By ....
(Authorized officer or agent.)
(Source: Laws 1943, vol. 2, p. 323.)
Notes of Decisions
Cited in 10
cases, 1997–2012 · leading case: NDC LLC v. Topinka, 871 N.E.2d 210 (Ill. App. Ct. 2007).
NDC LLC v. Topinka, 871 N.E.2d 210 (Ill. App. Ct. 2007). “1 of the Protest Act itself (30 ILCS 230/2a.1 (West 2004)). Section 2a.”
Milwaukee Safeguard Ins. v. Selcke, 688 N.E.2d 68 (Ill. 1997). “See 30 ILCS 230/2a.1 (West 1992). They then brought numerous suits alleging that the privilege tax is facially unconstitutional under the uniformity Clause of the Illinois Constitution of 1970 (Ill.”
Valstad Ex Rel. Valstad Quarry, Inc. v. Cipriano, 828 N.E.2d 854 (Ill. App. Ct. 2005). “1 of the State Officers and Employees Money Disposition Act (commonly referred to as the Protest Fund Act) (30 ILCS 230/2a.1 (West 2002)). Those fees ranged from $500 to $53,000 for individual plaintiffs and totaled $461,000.”
Hartney Fuel Co. v. Hamer, 2012 IL App (3d) 110144 (Ill. App. Ct. 2012). “08 MR 15) pursuant to the State Officers and Employees Money Disposition Act (Protest Monies Act) (30 ILCS 230/2a.1 (West 2008)). The first of these cases related to the disputed tax, and the second to IDOR’s refusal–starting in the fall of 2008–to remit the local portion of…”
Milwaukee Safeguard Ins. Co. v. Selcke, 754 N.E.2d 349 (Ill. App. Ct. 2001). “30 ILCS 230/2a.1 (West 1992). The trial court consolidated the suits.”
Nalco NDC LLC v. Judy Barr Topinka (Ill. App. Ct. 2007). “See 30 ILCS 230/2a.1 (West 2004). Later that day, Durchholz rejected in writing the form and payment, stating that the form would not be accepted unless the protest language were removed and the $5 filing fee were omitted from the protested payment.”
Wexler v. Wirtz Corp. (Ill. 2004). “30 ILCS 230/2a.1 (West 2000). That was not done here.”
Irwin Indus. Tool Co. v. Dep't of Revenue (Ill. 2010). “1 of the State Officers and Employees Money Disposition Act (30 ILCS 230/2a.1 (West 2008)), and filed a complaint seeking reimbursement.”
Valstad v. Cipriano (Ill. App. Ct. 2005). “1 of the State Officers and Employees Money Disposition Act (commonly referred to as the Protest Fund Act) (30 ILCS 230/2a.1 (West 2002)). Those fees ranged from $500 to $53,000 for individual plaintiffs and totaled $461,000.”
Milwaukee Safeguard v. Selcke (Ill. 1997). “See 30 ILCS 230/2a.1 (West 1992). They then brought numerous suits alleging that the privilege tax is facially unconstitutional under the uniformity clause of the Illinois Constitution of 1970 (Ill.”
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