Marathon Petroleum Co. LP v. Cook County Department of Revenue

Summary

The Illinois Supreme Court held that Marathon Petroleum successfully rebutted the Cook County Department of Revenue's prima facie case that its book‑out transactions were taxable sales, reversed the ALJ’s decision, and remanded for the Department to prove taxability. The Court applied a clearly erroneous standard to the ALJ’s factual findings and a de novo review to the legal definition of "sale" under the Fuel Tax Ordinance.