Illinois Compiled Statutes
35 ILCS 200/23-5 (2026)
Payment under protest
✓ current as of May 2026
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(35 ILCS 200/23-5)
Sec. 23-5.
Payment under protest.
Beginning with the 1994 tax year in
counties with 3,000,000 or more inhabitants, and beginning with the 1995 tax
year in all other counties, if
any person desires to object to all or any part of a property tax for any year,
for any
reason other than that the property is exempt from taxation, he or she shall
pay all of the tax due
within 60 days from the first penalty date of the final installment of taxes
for that year. Whenever taxes are paid in compliance with this Section and a
tax objection complaint is filed in compliance with Section 23-10, 100% of the
taxes shall be deemed paid under protest without the filing of a separate
letter of protest with the county collector.
(Source: P.A. 88-455; 89-126, eff. 7-1195.)
Notes of Decisions
Cited in 26
cases (8 in the last 5 years), 1998–2025 · 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)).”
Millennium Park Jt. Venture, LLC v. Houlihan, 948 N.E.2d 1 (Ill. 2010). “" 35 ILCS 200/23-5, 23-10 (West 2008). In contrast, a taxpayer can immediately mount a challenge with the Board of Review before any taxes are due and payable if the challenge is that the property was overassessed, underassessed, or is exempt under section 16-115.”
Reno v. Newport Twp., 2018 IL App (2d) 170967 (Ill. App. Ct. 2018). “We affirm the judgment dismissing the amended complaint, as plaintiff's exclusive remedy is through the tax-objection procedures outlined in article 23 of the Property Tax Code (see 35 ILCS 200/23-5 et seq.”
Sunnyside Elgin Apts., LLC v. Miller, 2021 IL App (2d) 200614 (Ill. App. Ct. 2021). “” 35 ILCS 200/23-5 (West 2018). In relevant part, it states: “Beginning with the 1994 tax year in counties with 3,000,000 or more inhabitants, and beginning with the 1995 tax year in all other counties, if any person desires to object to all or any part of a property tax for any…”
Millennium Park Jt. Venture, LLC v. Houlihan, 911 N.E.2d 517 (Ill. App. Ct. 2009). “35 ILCS 200/23-5, 23-10, 23-15 (West 2006).”
Cnty. Collector v. ATI Carriage House, Inc., 718 N.E.2d 164 (Ill. 1999). “675 (now codified at 35 ILCS 200/23-5 et seq. (West 1996))) to the application of the Du Page County collector for judgment on *166 their 1993 real estate taxes.”
Shawnee Cmty. Unit Sch. Dist. No. 84 v. Illinois Prop. Tax Appeal Bd., 2022 IL App (5th) 190266 (Ill. App. Ct. 2022). “The School District alleged that Grand Tower LLC failed to pay the taxes by the fall of 2015 “as required by 35 ILCS 200/23-5” and, instead, chose “to completely default on payment” of the taxes, resulting in the Jackson County circuit court entering a delinquency judgment and…”
1411 North State Condo. v. The Illinois Prop. Tax Appeal Bd., 2016 IL App (1st) 143757 (Ill. App. Ct. 2016). “35 ILCS 200/23-5 (West 2010); 86 Ill. Adm.”
Madison Two Assocs. v. Pappas, 862 N.E.2d 1184 (Ill. App. Ct. 2007). “35 ILCS 200/23-5 (West 2002). Section 23-10 sets forth a deadline by which a property owner must file a tax objection complaint.”
Shawnee Cmty. Unit Sch. Dist. No. 84 v. Illinois Prop. Tax Appeal Bd., 2024 IL 128731 (Ill. 2024). “As in the trial court and the appellate court (see 2022 IL App (5th) 190266, ¶¶ 45-58 ), the School District first argues in this court that the PTAB erred in denying its motion to dismiss because Illinois taxpayers are required “to make timely payments before seeking assessment…”
Aasen v. Rickert, 2018 IL App (2d) 170036 (Ill. App. Ct. 2018). “Proceedings ¶ 13 On October 1, 2015, the Objectors filed tax objection complaints against the Collector, pursuant to section 23-5 of the Code ( 35 ILCS 200/23-5 (West 2014) ), alleging that the Kane County clerk's application of the amended apportionments for tax year 2012 to…”
In Re Application of Du Page Cnty. Collector, 691 N.E.2d 405 (Ill. App. Ct. 1998). “January 1, 1994, and now recodified at 35 ILCS 200/23-5 et seq. (West 1996))). Objectors alleged that the levy was void as being violative of section 17-1 of the School Code (105 ILCS 5/17-1 (West 1996)).”
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