Illinois Compiled Statutes
35 ILCS 200/23-10 (2026)
Tax objections and copies
✓ current as of May 2026
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(35 ILCS 200/23-10)
Sec. 23-10.
Tax objections and copies.
Beginning with the 2003
tax year, in
counties with 3,000,000 or more inhabitants, the person paying the taxes due
as provided in Section 23-5 may file
a tax
objection
complaint under Section 23-15 within 165 days after the first
penalty
date of the final installment of taxes for the year in question.
Beginning with the 2003 tax year, in counties with less than 3,000,000
inhabitants, the person paying the taxes
due as provided in Section 23-5 may file a tax objection complaint under
Section 23-15 within 75 days after the first penalty date of the final
installment of taxes for the year in question.
However, in all counties in cases in which the complaint is permitted to be
filed without
payment under Section 23-5, it must be filed prior to the entry of judgment
under Section 21-175. In addition, the time specified for payment of the tax
provided in Section 23-5 shall not be construed to delay or prevent the entry
of judgment against, or the sale of, tax delinquent property if the taxes have
not been paid prior to the entry of judgment under Section 21-175.
An objection to an assessment for any year shall not be
allowed by the court, however, if an administrative remedy was available by
complaint to the board of appeals or board of review under Section 16-55 or
Section 16-115, unless that remedy was exhausted prior to the filing of the tax
objection complaint.
When any complaint is filed with the court in a
county
with less than
3,000,000 inhabitants, the plaintiff shall
file 3 copies of
the complaint with the clerk of the circuit court. Any
complaint
or amendment
thereto shall contain (i) on the first page a listing of the taxing
districts
against which the complaint is directed
and (ii) a summary of the
reasons
for the tax
objections set
forth in the complaint with enough copies of the summary to be distributed to
each of the
taxing districts against which the complaint is directed.
Within 10 days after
the complaint is
filed, the clerk of the circuit court shall deliver one copy to the State's
Attorney and one copy to the county clerk, taking their receipts therefor. The
county clerk shall, within 30 days from the last day for the filing of
complaints, notify the duly elected or appointed custodian
of funds for each
taxing district that may be affected by the complaint,
stating (i) that a complaint has been filed and (ii) the
summary of the reasons for the tax objections set forth in the complaint.
Any amendment to a
complaint,
except any amendment
permitted to be made in open court during the course of a hearing on the
complaint, shall also be filed in triplicate, with one copy
delivered to the
State's Attorney and one copy delivered to the county clerk by the clerk of the
circuit court. The State's Attorney shall within 10 days of receiving his or
her copy of the amendment notify the duly elected or appointed custodian of
funds for each taxing district whose tax monies may be affected by the
amendment, stating (i) that the amendment has been filed and (ii) the
summary of the reasons for the tax objections set forth in the amended
complaint.
The State's Attorney shall also notify the custodian and the county
clerk in writing of the date, time and place of any hearing before the court to
be held upon the complaint or amended complaint not later than 4 days prior to
the hearing. The notices provided in this Section shall
be by letter addressed to the custodian or the county clerk and may be
mailed by regular mail, postage prepaid, postmarked within the required period,
but not less than 4 days before a hearing.
(Source: P.A. 93-378, eff. 7-24-03.)
Notes of Decisions
Cited in 18
cases (5 in the last 5 years), 2007–2025 · leading case: Madison Two Assocs. v. Pappas, 884 N.E.2d 142 (Ill. 2008).
Madison Two Assocs. v. Pappas, 884 N.E.2d 142 (Ill. 2008). “November 26, 2007)), or (2) it could have paid the real estate tax due on the property (see 35 ILCS 200/23-5 (West 2002)), and then filed a "tax objection complaint" with the circuit court of Cook County (see 35 ILCS 200/23-10 (West 2002)). [2] Where valuation is at issue, as is…”
Millennium Park Jt. Venture, LLC v. Houlihan, 948 N.E.2d 1 (Ill. 2010). “NOTES [1] The statutory scheme, however, provides that "[a]n objection to an assessment for any year shall not be allowed by the court * * * if an administrative remedy was available by complaint to the * * * board of review under * * * [s]ection 16-115, unless that remedy was…”
Reno v. Newport Twp., 2018 IL App (2d) 170967 (Ill. App. Ct. 2018). “" 35 ILCS 200/23-10 (West 2016). A property owner must exhaust any available administrative remedies before filing a tax-objection complaint.”
Madison Two Assocs. v. Pappas, 862 N.E.2d 1184 (Ill. App. Ct. 2007). “35 ILCS 200/23-10 (West 2002). Section 23-15, sets forth additional procedural details and states as follows: *1188 "§ 23-15.”
Shawnee Cmty. Unit Sch. Dist. No. 84 v. Illinois Prop. Tax Appeal Bd., 2024 IL 128731 (Ill. 2024). “See 35 ILCS 200/23-10 (West 2014). Even after it filed the initial appeal to PTAB, it had the option of withdrawing the appeal to pursue instead the court proceeding.”
Hawkins v. Far South CDC, Inc., 2013 IL App (1st) 121707 (Ill. App. Ct. 2014). “35 ILCS 200/23-10, 23-15(a) (West 2012). The complaint must name the county collector as defendant and “specify any objections that the plaintiff may have to the taxes in question,” but “no complaint shall be filed as a class action.”
Shawnee Cmty. Unit Sch. Dist. No. 84 v. Illinois Prop. Tax Appeal Bd., 2024 IL 128731 (Ill. 2024). “See 35 ILCS 200/23-10 (West 2014). Even after it filed the initial appeal to PTAB, it had the option of withdrawing the appeal to pursue instead the court proceeding.”
Hawkins v. Far South, Inc., 2013 IL App (1st) 121707 (Ill. App. Ct. 2013). “35 ILCS 200/23-10, 23-15(a) (West 2012). The complaint must name the county collector as defendant and "specify any objections that the plaintiff may have to the taxes in question," but “no complaint shall be filed as a class action.”
Slabon v. Cook Cnty., 2024 IL App (1st) 231170-U (Ill. App. Ct. 2024). “See 35 ILCS 200/23-10 (West 2020) (“An objection to an assessment for any year shall not be allowed by the court, however, if an administrative remedy was available by complaint to the board of appeals or board of review *** unless that remedy was exhausted prior to the filing…”
Carle Found. v. Illinois Dep't of Revenue (Ill. App. Ct. 2009). “In its motion for dismissal pursuant to section 2-615 of the Code of Civil Procedure (735 ILCS 5/2-615 (West 2006)), the Department argued that section 23- 25(e) (35 ILCS 200/23-25(e) (West 2006)) did not create a private right of action and that the Foundation's…”
Passco Mellody Farm DST Trust v. Kim, 2025 IL App (2d) 240329 (Ill. App. Ct. 2025). “35 ILCS 200/23-10, 23-15 (West 2020). After a bench trial, the circuit court entered judgment in plaintiff’s favor.”
IP Plaza v. Bean, 2011 IL App (4th) 110244 (Ill. App. Ct. 2011). “Court Proceedings ¶ 16 In November 2007, IP Plaza filed a tax-objection complaint pursuant to sections 23-10 and 23-25 of the Property Tax Code (35 ILCS 200/23-10, 23-25 (West 2006)). IP Plaza claimed the supervisor of assessments incorrectly revoked the property’s exempt…”
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