Illinois Compiled Statutes
35 ILCS 200/22-20 (2026)
Proof of service of notice; publication of notice
✓ current as of May 2026
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(35 ILCS 200/22-20)
Sec. 22-20. Proof of service of notice; publication of notice. The sheriff or coroner serving notice under Section 22-15 shall
endorse his or
her return thereon and file it with the Clerk of the Circuit Court and it shall
be a part of the court record. A private detective or a special process server appointed under
Section
22-15 shall make his or her return by affidavit and shall file it with the
Clerk of the Circuit Court, where it shall be a part of the court record. If
a sheriff, private detective, special process server, or coroner to whom any notice is
delivered for service, neglects or refuses to make the return, the purchaser or
his or her assignee may petition the court to enter a rule requiring the
sheriff, private detective, special process server, or coroner to make return of the notice on
a day to be fixed by the
court, or to show cause on that day why he or she should not be attached for
contempt of the court. The purchaser or assignee shall cause a written notice
of the rule to be served upon the sheriff, private detective, special process server, or
coroner. If good and sufficient cause to excuse the sheriff, private detective, special process
server, or coroner is not shown, the court shall adjudge him or her guilty of
a contempt, and shall proceed to punish him as in other cases of contempt.
If the property is located in a municipality in a county with less than
3,000,000 inhabitants, the purchaser or his or her assignee shall also publish
a notice as to the owner or party interested, in some newspaper published in
the municipality. If the property is not in a municipality in a county with
less than 3,000,000 inhabitants, or if no newspaper is published therein, or
if the property is in a county with 3,000,000 or more inhabitants, the notice
shall be published in some newspaper in the county. If no newspaper is
published in the county, then the notice shall be published in the newspaper
that is published nearest the county seat of the county in which the property
is located. If the owners and parties interested in the property upon diligent
inquiry are unknown to the purchaser or his or her assignee, the publication as
to such owner or party interested, may be made to unknown owners or parties
interested. Any notice by publication given under this Section shall be given
3 times at any time after filing a petition for tax deed, but not less than 3
months nor more than 6 months prior to the expiration of the period of
redemption. The publication shall contain (a) notice of the filing of the
petition for tax deed, (b) the date on which the petitioner intends to make
application for an order on the petition that a tax deed issue, (c) a
description of the property, (d) the date upon which the property was sold, (e)
the taxes or special assessments for which it was sold and (f) the date on
which the period of redemption will expire. The publication shall not include
more than one property listed and sold in one description, except as provided
in Section 21-90, and except that when
more than one property is owned by one person, all of the parcels owned by that
person may be included in one notice.
The changes to this Section made by Public Act 95-477
apply only to matters in which a petition for tax deed is filed on or after June 1, 2008 (the effective date of Public Act 95-477).(Source: P.A. 95-195, eff. 1-1-08; 95-477, eff. 6-1-08; 95-876, eff. 8-21-08.)
Notes of Decisions
Cited in 29
cases (5 in the last 5 years), 1994–2026 · leading case: In Re Application of Cnty. Treasurer, 824 N.E.2d 614 (Ill. 2005).
In Re Application of Cnty. Treasurer, 824 N.E.2d 614 (Ill. 2005). “Article 22 provides, inter alia, for notice of the sale and of the property owner's redemption rights (35 ILCS 200/22-5 (West 2000)); notice of the expiration of the period of redemption (35 ILCS 200/22-10 (West 2000)); notice by publication (35 ILCS 200/22-20 (West 2000)); a…”
In re Application of the Cnty. Treasurer & ex officio Cnty. Collector, 2022 IL App (1st) 211511 (Ill. App. Ct. 2022). “Article 22 provides, inter alia, for notice of the sale and of the property owner’s redemption rights (35 ILCS 200/22-5 (West 2018)); notice of the expiration of the period of redemption (35 ILCS 200/22-10 (West 2018)); notice by publication (35 ILCS 200/22-20 (West 2018)); a…”
DG Enter. v. Cornelius, 2015 IL 118975 (Ill. 2015). “” 35 ILCS 200/22-20 (West 2010). ¶ 11 On July 6, 2011, the same day it filed its petition for tax deed, the petitioner placed the take notices required by section 22-25 for mailing with the clerk of the circuit court of Will County.”
DG Enter. v. Cornelius, 2015 IL 118975 (Ill. 2016). “See 35 ILCS 200/22-20 (West 2010). ¶ 29 We therefore conclude, as the appellate court dissent did, that respondent’s failure to prove or even allege that petitioner did not name respondent in the notices prevented respondent from establishing grounds for relief under section…”
Butler v. Lejcar (In Re Butler), 171 B.R. 321 (Bankr. N.D. Ill. 1994). “3) Expiration of Right of Redemption— After completing the state law procedural and substantive requirements, the certificate holder may obtain the tax deed.”
In Re Cnty. Treasurer, 837 N.E.2d 947 (Ill. App. Ct. 2005). “Section 22-10 of the Property Tax Code provides that a purchaser shall not be entitled to a tax deed to the property sold unless he gives written notice of the sale and the date of expiration of the period of redemption to the owners, occupants and parties interested in the…”
In Re Application of Cnty. Collector, 838 N.E.2d 907 (Ill. 2005). “As required by statute (see 35 ILCS 200/22-20 (West 1994)), the Cook County sheriff filed the returns of service for the section 22-10 take notices with the clerk of the circuit court.”
In Re Halas, 194 B.R. 605 (Bankr. N.D. Ill. 1996). “According to 35 ILCS 200/22-20, to obtain a tax deed, he must first petition for a deed “at any time within 5 months but not less than three months prior to the expiration of the redemption period,” and notice of such hearing must be given.”
In Re Ward, 724 N.E.2d 1 (Ill. App. Ct. 2000). “The Code requires that a tax purchaser or his assignee serve notice, by abode service and by certified mail, upon "parties interested in the property, if upon diligent inquiry they can be found in the county.”
In re Application of the Cnty. Treasurer & ex officio Cnty. Collector, 2013 IL App (1st) 130103 (Ill. App. Ct. 2014). “35 ILCS 200/22-20 (West 2008). Section 22-25 also bases the notice required on the form of section 22-10.”
In re Application of Skidmore, 2018 IL App (2d) 170369 (Ill. App. Ct. 2018). “Section 22-20 (35 ILCS 200/22-20 (West 2016)) requires that the sheriff’s return of service and proof of publication be filed with the circuit clerk.”
In re: The Application of the Douglas Cnty. Treasurer, 2014 IL App (4th) 130261 (Ill. App. Ct. 2014). “" 35 ILCS 200/22-20 (West 2010). As discussed further below, a "diligent inquiry" is an inquiry "as full as the circumstances of the situation will permit.”
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