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104TH GENERAL ASSEMBLY
State of Illinois
2025 and 2026
SB2964

Introduced 1/27/2026, by Sen. Cristina Castro

SYNOPSIS AS INTRODUCED:

35 ILCS 200/6-60
35 ILCS 200/12-50
35 ILCS 200/16-55
35 ILCS 200/16-115
35 ILCS 200/16-180
35 ILCS 200/16-185
35 ILCS 200/23-15

Amends the Property Tax Code. Provides that a complainant before the
board of review or the Property Tax Appeal Board may represent himself or
herself or designate a representative to appear before the board on his or
her behalf. Provides that the description of rules and procedures provided
by the board of review to the public must include an explanation that the
taxpayer may appear pro se or be represented by any other person, including
but not limited to an attorney, accountant, or other tax representative.
Provides that the assessor or the board of review has the burden of proving
any contested matter of fact by a preponderance of the evidence
(currently, the plaintiff has the burden of proof by clear and convincing
evidence).
LRB104 17058 HLH 30473 b

A BILL FOR

SB2964
LRB104 17058 HLH 30473 b
1

AN ACT concerning revenue.

2

Be it enacted by the People of the State of Illinois,
3
represented in the General Assembly:

4

Section 5.
The Property Tax Code is amended by changing
5
Sections 6-60, 12-50, 16-55, 16-115, 16-180, 16-185, and 23-15
6
as follows:

7

(35 ILCS 200/6-60)
8

Sec. 6-60.
Rules and procedures.
The board of review in
9
every county with less than 3,000,000 inhabitants must make
10
available to the public a detailed description of the rules
11
and procedures for hearings before the board. This description
12
must include an explanation of any applicable burdens of
13
proof, rules of evidence, timelines, and any other procedures
14
that will allow the taxpayer to effectively present his or her
15
case before the board.
The description must include an
16
explanation that the taxpayer may appear pro se or be
17
represented by any other person, including, but not limited
18
to, an attorney, accountant, or other tax representative.
If a
19
county Internet website exists, the rules and procedures must
20
also be published on that website.
21
(Source: P.A. 96-122, eff. 1-1-10.)

22

(35 ILCS 200/12-50)

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LRB104 17058 HLH 30473 b
1

Sec. 12-50.
Mailed notice to taxpayer after change by
2
board of review or board of appeals.
In counties with less than
3
3,000,000 inhabitants, if final board of review or board of
4
appeals action regarding any property, including equalization
5
under Section 16-60 or Section 16-65, results in an increased
6
or decreased assessment, the board shall mail a notice to the
7
taxpayer whose property is affected by such action, at his or
8
her address as it appears on the complaint, unless the
9
taxpayer has been represented in the appeal by
a
10
representative

an attorney
, in which case the notice shall be
11
mailed to the
representative

attorney
, and in the case of a
12
complaint filed with a board of review under Section 16-25 or
13
16-115, the board shall mail a notice to the taxing body filing
14
the complaint. In counties with 3,000,000 or more inhabitants,
15
the board shall provide notice by mail, or by means of
16
electronic record, to the taxpayer whose property is affected
17
by such action, at his or her address or e-mail address as it
18
appears in the assessment records or a complaint filed with
19
the board, unless the taxpayer has been represented in the
20
appeal by
a representative

an attorney
, in which case the
21
notice shall be mailed or e-mailed to the
representative

22
attorney
, and, in the case of a complaint filed with a board of
23
review under Section 16-125 or 16-115, the board shall provide
24
notice to the taxing body filing the complaint. A copy shall be
25
given to the assessor or chief county assessment officer if
26
his or her assessment was reversed or modified by the board.

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1
Written notice shall also be given to any taxpayer who filed a
2
complaint in writing with the board and whose assessment was
3
not changed. The notice shall set forth the assessed value
4
prior to board action; the assessed value after final board
5
action but prior to any equalization; and the assessed value
6
as equalized by the board, if the board equalizes. This notice
7
shall state that the value as certified to the county clerk by
8
the board will be the locally assessed value of the property
9
for that year and each succeeding year, unless revised in a
10
succeeding year in the manner provided in this Code. The
11
written notice shall also set forth specifically the facts
12
upon which the board's decision is based. In counties with
13
less than 3,000,000 inhabitants, the notice shall also contain
14
the following statement: "You may appeal this decision to the
15
Property Tax Appeal Board by filing a petition for review with
16
the Property Tax Appeal Board within 30 days after this notice
17
is mailed to you or your agent, or is personally served upon
18
you or your agent". In counties with 3,000,000 or more
19
inhabitants, the notice shall also contain the following
20
statement: "You may appeal this decision to the Property Tax
21
Appeal Board by filing a petition for review with the Property
22
Tax Appeal Board within 30 days after the date of this notice
23
or within 30 days after the date that the Board of Review
24
transmits to the county assessor pursuant to Section 16-125
25
its final action on the township in which your property is
26
located, whichever is later". The Board shall publish its

SB2964
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1
transmittal date of final action on each township in at least
2
one newspaper of general circulation in the county. The
3
changes made by this amendatory Act of the 91st General
4
Assembly apply to the 1999 assessment year and thereafter.
5
(Source: P.A. 97-1054, eff. 1-1-13.)

6

(35 ILCS 200/16-55)
7

Sec. 16-55.
Complaints.

8

(a) On written complaint that any property is overassessed
9
or underassessed, the board shall review the assessment, and
10
correct it, as appears to be just, but in no case shall the
11
property be assessed at a higher percentage of fair cash value
12
than other property in the assessment district prior to
13
equalization by the board or the Department.
14

(b) The board shall include compulsory sales in reviewing
15
and correcting assessments, including, but not limited to,
16
those compulsory sales submitted by the complainant, if the
17
board determines that those sales reflect the same property
18
characteristics and condition as those originally used to make
19
the assessment. The board shall also consider whether the
20
compulsory sale would otherwise be considered an arm's length
21
transaction.
22

(c)
The complainant may represent himself or herself or
23
designate a representative to appear before the board on his
24
or her behalf.
If a complaint is filed by
a representative

an
25
attorney
on behalf of a complainant, all notices and

SB2964
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LRB104 17058 HLH 30473 b
1
correspondence from the board relating to the appeal shall be
2
directed to the
representative.

attorney. The board may
3
require proof of the attorney's authority to represent the
4
taxpayer. If the attorney fails to provide proof of authority
5
within the compliance period granted by the board pursuant to
6
subsection (d), the board may dismiss the complaint.
The Board
7
shall send, electronically or by mail, notice of the dismissal
8
to the attorney and complainant.
9

(d) A complaint to affect the assessment for the current
10
year shall be filed on or before 30 calendar days after the
11
date of publication of the assessment list under Section
12
12-10. Upon receipt of a written complaint that is timely
13
filed under this Section, the board of review shall docket the
14
complaint. If the complaint does not comply with the board of
15
review rules adopted under Section 9-5 entitling the
16
complainant to a hearing, the board shall send, electronically
17
or by mail, notification acknowledging receipt of the
18
complaint. The notification must identify which rules have not
19
been complied with and provide the complainant with not less
20
than 10 business days to bring the complaint into compliance
21
with those rules. If the complainant complies with the board
22
of review rules either upon the initial filing of a complaint
23
or within the time as extended by the board of review for
24
compliance, then the board of review shall send,
25
electronically or by mail, a notice of hearing and the board
26
shall hear the complaint and shall issue and send,

SB2964
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LRB104 17058 HLH 30473 b
1
electronically or by mail, a decision upon resolution. Except
2
as otherwise provided in subsection (c), if the complainant
3
has not complied with the rules within the time as extended by
4
the board of review, the board shall nonetheless issue and
5
send a decision. The board of review may adopt rules allowing
6
any party to attend and participate in a hearing by telephone
7
or electronically.
8

(d-5) Complaints and other written correspondence sent by
9
the United States mail shall be considered filed as of the
10
postmark date in accordance with Section 1.25 of the Statute
11
on Statutes. Complaints and other written correspondence sent
12
by a delivery service other than the United States Postal
13
System shall be considered as filed as of the date sent as
14
indicated by the shipper's tracking label. If allowed by board
15
of review rule, complaints and other written correspondence
16
transmitted electronically shall be considered filed as of the
17
date received.
18

(e) The board may also, at any time before its revision of
19
the assessments is completed in every year, increase, reduce
20
or otherwise adjust the assessment of any property, making
21
changes in the valuation as may be just, and shall have full
22
power over the assessment of any person and may do anything in
23
regard thereto that it may deem necessary to make a just
24
assessment, but the property shall not be assessed at a higher
25
percentage of fair cash value than the assessed valuation of
26
other property in the assessment district prior to

SB2964
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LRB104 17058 HLH 30473 b
1
equalization by the board or the Department.
2

(f) No assessment shall be increased until the person to
3
be affected has been notified and given an opportunity to be
4
heard, except as provided below.
5

(g) Before making any reduction in assessments of its own
6
motion, the board of review shall give notice to the assessor
7
or chief county assessment officer who certified the
8
assessment, and give the assessor or chief county assessment
9
officer an opportunity to be heard thereon.
10

(h) All complaints of errors in assessments of property
11
shall be in writing, and shall be filed by the complaining
12
party with the board of review, in the number of copies
13
required by board of review rule. A copy shall be filed by the
14
board of review with the assessor or chief county assessment
15
officer who certified the assessment.
16

(i) In all cases where a change in assessed valuation of
17
$100,000 or more is sought, the board of review shall also
18
serve a copy of the petition on all taxing districts as shown
19
on the last available tax bill at least 14 days prior to the
20
hearing on the complaint. Service may be by electronic means
21
if the taxing district consents to electronic service and
22
provides the board of review with a valid e-mail address for
23
the purpose of receiving service. All taxing districts shall
24
have an opportunity to be heard on the complaint. A taxing
25
district wishing to intervene shall file a request to
26
intervene with the board of review at least five days in

SB2964
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LRB104 17058 HLH 30473 b
1
advance of a scheduled hearing. If board of review rules
2
require the appellant to submit evidence in advance of a
3
hearing, then any evidence in support of the intervenor's
4
opinion of assessed value must be submitted to the board of
5
review and complainant no later than five calendar days prior
6
to the hearing. Service shall be made as set forth in
7
subsection (d-5), but if board of review rules allow
8
complaints and correspondence to be transmitted
9
electronically, then the intervenor's evidence shall be
10
transmitted electronically.
11

(i-5) If board of review rules require the appellant to
12
submit evidence in advance of a hearing, then any evidence to
13
support the assessor's opinion of assessed value must be
14
submitted to the board of review and
either
the complainant
15
or, if the complainant is represented, the complainant's
16
representative

(or, if represented by an attorney, to the
17
attorney)
no later than five calendar days prior to the
18
hearing. Service shall be made as set forth in subsection
19
(d-5), but if board of review rules allow complaints and
20
correspondence to be transmitted electronically, then the
21
assessor's evidence shall be transmitted electronically.
22

(j) Complaints shall be classified by townships or taxing
23
districts by the clerk of the board of review. All classes of
24
complaints shall be docketed numerically, each in its own
25
class, in the order in which they are presented, in books kept
26
for that purpose, which books shall be open to public

SB2964
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LRB104 17058 HLH 30473 b
1
inspection. Complaints shall be considered by townships or
2
taxing districts until all complaints have been heard and
3
passed upon by the board.
4
(Source: P.A. 98-322, eff. 8-12-13; 99-98, eff. 1-1-16;
5
99-579, eff. 7-15-16.)

6

(35 ILCS 200/16-115)
7

Sec. 16-115.
Filing complaints.
In counties with 3,000,000
8
or more inhabitants, complaints that any property is
9
overassessed or underassessed or is exempt may be made by any
10
taxpayer.
A taxpayer may represent himself or herself or
11
designate a representative to file the complaint and appear on
12
his or her behalf.
Complaints that any property is
13
overassessed or underassessed or is exempt may be made by a
14
taxing district that has an interest in the assessment to a
15
board of review. All complaints shall be in writing, identify
16
and describe the particular property, otherwise comply with
17
the rules in force, be either signed by the complaining party
18
or his or her
representative

attorney
or, if filed
19
electronically, signed with the electronic signature of the
20
complaining party or his or her
representative

attorney
, and
21
be filed with the board of appeals (until the first Monday in
22
December 1998 and the board of review beginning the first
23
Monday in December 1998 and thereafter) in at least duplicate.
24
The board shall forward one copy of each complaint to the
25
county assessor.

SB2964
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LRB104 17058 HLH 30473 b
1

Complaints by taxpayers and taxing districts and
2
certificates of correction by the county assessor as provided
3
in this Code shall be filed with the board according to
4
townships on or before the dates specified in the notices
5
given in Section 16-110.
6
(Source: P.A. 97-1054, eff. 1-1-13.)

7

(35 ILCS 200/16-180)
8

Sec. 16-180.
Procedure for determination of correct
9
assessment.
The Property Tax Appeal Board shall establish by
10
rules an informal procedure for the determination of the
11
correct assessment of property which is the subject of an
12
appeal. The procedure, to the extent that the Board considers
13
practicable, shall eliminate formal rules of pleading,
14
practice and evidence, and except for any reasonable filing
15
fee determined by the Board, may provide that costs shall be in
16
the discretion of the Board. A copy of the appellant's
17
petition shall be mailed or sent by electronic means by the
18
clerk of the Property Tax Appeal Board to the board of review
19
whose decision is being appealed. In all cases where a change
20
in assessed valuation of $100,000 or more is sought, the board
21
of review shall serve a copy of the petition on all taxing
22
districts as shown on the last available tax bill. The
23
chairman of the Property Tax Appeal Board shall provide for
24
the speedy hearing of all such appeals.
The appellant may
25
represent himself or herself or designate a representative to

SB2964
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LRB104 17058 HLH 30473 b
1
appear before the Board on his or her behalf.
Each appeal shall
2
be limited to the grounds listed in the petition filed with the
3
Property Tax Appeal Board. All appeals shall be considered de
4
novo and the Property Tax Appeal Board shall not be limited to
5
the evidence presented to the board of review of the county. A
6
party participating in the hearing before the Property Tax
7
Appeal Board is entitled to introduce evidence that is
8
otherwise proper and admissible without regard to whether that
9
evidence has previously been introduced at a hearing before
10
the board of review of the county. Where no complaint has been
11
made to the board of review of the county where the property is
12
located and the appeal is based solely on the effect of an
13
equalizing factor assigned to all property or to a class of
14
property by the board of review, the Property Tax Appeal Board
15
shall not grant a reduction in assessment greater than the
16
amount that was added as the result of the equalizing factor.
17

The provisions added to this Section by this amendatory
18
Act of the 93rd General Assembly shall be construed as
19
declaratory of existing law and not as a new enactment.
20
(Source: P.A. 99-626, eff. 7-22-16.)

21

(35 ILCS 200/16-185)
22

Sec. 16-185.
Decisions.
The Board shall make a decision in
23
each appeal or case appealed to it, and the decision shall be
24
based upon equity and the weight of evidence and not upon
25
constructive fraud, and shall be binding upon appellant and

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LRB104 17058 HLH 30473 b
1
officials of government. The extension of taxes on any
2
assessment so appealed shall not be delayed by any proceeding
3
before the Board, and, in case the assessment is altered by the
4
Board, any taxes extended upon the unauthorized assessment or
5
part thereof shall be abated, or, if already paid, shall be
6
refunded with interest as provided in Section 23-20.
7

The decision or order of the Property Tax Appeal Board in
8
any such appeal, shall, within 10 days thereafter, be
9
certified at no charge to the appellant and to the proper
10
authorities, including the board of review or board of appeals
11
whose decision was appealed, the county clerk who extends
12
taxes upon the assessment in question, and the county
13
collector who collects property taxes upon such assessment.

14

The final administrative decision of the Property Tax
15
Appeal Board shall be deemed served on a party when a copy of
16
the decision is: (1) deposited in the United States Mail, in a
17
sealed package, with postage prepaid, addressed to that party
18
at the address listed for that party in the pleadings; except
19
that, if the party is represented by
a representative

an
20
attorney
, the notice shall go to the
representative

attorney

21
at the address listed in the pleadings; or (2) sent
22
electronically to the party at the e-mail addresses provided
23
for that party in the pleadings. The Property Tax Appeal Board
24
shall allow each party to designate one or more individuals to
25
receive electronic correspondence on behalf of that party and
26
shall allow each party to change, add, or remove designees

SB2964
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LRB104 17058 HLH 30473 b
1
selected by that party during the course of the proceedings.
2
Decisions and all electronic correspondence shall be directed
3
to each individual so designated.
4

If the Property Tax Appeal Board renders a decision
5
lowering the assessment of a particular parcel after the
6
deadline for filing complaints with the board of review or
7
board of appeals or after adjournment of the session of the
8
board of review or board of appeals at which assessments for
9
the subsequent year or years of the same general assessment
10
period, as provided in Sections 9-215 through 9-225, are being
11
considered, the taxpayer may, within 30 days after the date of
12
written notice of the Property Tax Appeal Board's decision,
13
appeal the assessment for such subsequent year or years
14
directly to the Property Tax Appeal Board.
15

If the Property Tax Appeal Board renders a decision
16
lowering the assessment of a particular parcel on which a
17
residence occupied by the owner is situated, such reduced
18
assessment, subject to equalization, shall remain in effect
19
for the remainder of the general assessment period as provided
20
in Sections 9-215 through 9-225, unless that parcel is
21
subsequently sold in an arm's length transaction establishing
22
a fair cash value for the parcel that is different from the
23
fair cash value on which the Board's assessment is based, or
24
unless the decision of the Property Tax Appeal Board is
25
reversed or modified upon review.
26
(Source: P.A. 99-626, eff. 7-22-16; 100-216, eff. 8-18-17.)

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LRB104 17058 HLH 30473 b
1

(35 ILCS 200/23-15)
2

Sec. 23-15.
Tax objection procedure and hearing.
3

(a) A tax objection complaint under Section 23-10 shall be
4
filed in the circuit court of the county in which the subject
5
property is located. Joinder of plaintiffs shall be permitted
6
to the same extent permitted by law in any personal action
7
pending in the court and shall be in accordance with Section
8
2-404 of the Code of Civil Procedure; provided, however, that
9
no complaint shall be filed as a class action. The complaint
10
shall name the county collector as defendant and shall specify
11
any objections that the plaintiff may have to the taxes in
12
question. No appearance or answer by the county collector to
13
the tax objection complaint, nor any further pleadings, need
14
be filed. Amendments to the complaint may be made to the same
15
extent which, by law, could be made in any personal action
16
pending in the court.
17

(b) (1) The court, sitting without a jury, shall hear and
18
determine all objections specified to the taxes, assessments,
19
or levies in question. This Section shall be construed to
20
provide a complete remedy for any claims with respect to those
21
taxes, assessments, or levies, excepting only matters for
22
which an exclusive remedy is provided elsewhere in this Code.
23

(2) The taxes, assessments, and levies that are the
24
subject of the objection shall be presumed correct and legal,
25
but the presumption is rebuttable. The
assessor or board of

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LRB104 17058 HLH 30473 b
1
review

plaintiff
has the burden of proving any contested
2
matter of fact by
a preponderance of the

clear and convincing

3
evidence.
4

(3) Objections to assessments shall be heard de novo by
5
the court. The court shall grant relief in the cases in which
6
the objector meets the burden of proof under this Section and
7
shows an assessment to be incorrect or illegal. If an
8
objection is made claiming incorrect valuation, the court
9
shall consider the objection without regard to the correctness
10
of any practice, procedure, or method of valuation followed by
11
the assessor, board of appeals, or board of review in making or
12
reviewing the assessment, and without regard to the intent or
13
motivation of any assessing official. The doctrine known as
14
constructive fraud is hereby abolished for purposes of all
15
challenges to taxes, assessments, or levies.
16

(c) If the court orders a refund of any part of the taxes
17
paid, it shall also order the payment of interest as provided
18
in Section 23-20. Appeals may be taken from final judgments as
19
in other civil cases.
20

(d) This amendatory Act of 1995 shall apply to all tax
21
objection matters still pending for any tax year, except as
22
provided in Sections 23-5 and 23-10 regarding procedures and
23
time limitations for payment of taxes and filing tax objection
24
complaints.
25

(e) In counties with less than 3,000,000 inhabitants, if
26
the court renders a decision lowering the assessment of a

SB2964
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LRB104 17058 HLH 30473 b
1
particular parcel on which a residence occupied by the owner
2
is situated, the reduced assessment, subject to equalization,
3
shall remain in effect for the remainder of the general
4
assessment period as provided in Sections 9-215 through 9-225,
5
unless that parcel is subsequently sold in an arm's length
6
transaction establishing a fair cash value for the parcel that
7
is different from the fair cash value on which the court's
8
assessment is based, or unless the decision of the court is
9
reversed or modified upon review.
10
(Source: P.A. 88-455; 88-642, eff. 9-9-94; 89-126, eff.
11
7-11-95; 89-290, eff. 1-1-96; 89-593, eff. 8-1-96; 89-626,
12
eff. 8-9-96.)

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