instructions for the forms of state if i was a visual reminder of what we're dealing with here today this case is about an illinois state tax issue probably something you don't get to hear about very much and it's about something called the credit for tax on prior trades hours often called c t p t which i'll probably get was half of the time ok and and it has to do with a concept in the federal tax law that size that when there are success of the state pacifically about this credit for tax on prior transfers wasn't would be allowed in certain circumstances in illinois we don't know what the circumstances were in the mind of the person who spoke but the position of the attorney and the state of illinois said that's it will take ok you calculate that number the barrels the government says we can have that and that's what will take all the will gets everyone uses this and relies on it because otherwise you don't know what to do when your tax returns there's no other way to do the calculations u and it's kind of complicated if you can see that in our brief the bottom line is that it's always a wash the man money was the same the question became who got it right and so most taxpayers and how annoying didn't bother to reduce the  or to the states all my money ok so the fact that maybe the state wasn't losing anything to the crowd it was a political choice by the taxpayer not built into the actual wall the interesting thing about all of this is that and the point is that in order to understand the entire system you must need it if you just take each piece and say this is the year i'm seeing this one and this one and this one and read them literally you can't get a comprehensive system that is constitutional that is consistent that the taxpayers can follow and that they can understand you can't get to the kinds of things that work comprehensively as a whole and all of this federal law is in or it's not and then we lose especially for the states and the gap consistency uniformity tax credit against the illinois state tax based on what she what counsel is explained is a federal prior transfer credit under the internal revenue code should not she does should affirm that judgment and three reasons st the plain language of the illinois state act and then the when we amended the act after the federal reconciliation act phased out estate tax credit was based basically then on a hypothetical was based on the former state tax credit what you would have been able to since you can get under the old system a dollar for dollar credit for that one hundred dollars for that one hundred thousand dollars our system our pick up taxes to pick up an entire one hundred thousand dollars so you getting a four hundred thousand dollars credit we do sing federal estate tax by the one hundred magical case recognize the new system was was intended to continue to get that same full amount owed and that case the taxpayer is still trying to argue that hey what if i just don't claim any of my state tax or my full state tax credit in the that means that everything we lead stands was admitted why that is important you've heard counsel for the attorney general speculate that what we have pointed out is simply wrong he has said that this is never been the practice of the attorney general's office and it has never happened well st of all you've got to admit this court must look at this case as go it didn't happen because we and the creditors actually wire transfers has been used since the period of what i call the cut this period post two thousand and one so i might ask to the court to your honor's question earlier about preserving tax if the attorney general's interpretation is correct that tax will be increased and that is because in certain instances the amount of credit that was used to be allowable under the federal return or the amount of federal tax that might be due limits be able to a tax if all you do is take the taxable state and apply the credit o'loghlin table which is what we've just heard said that should be done you will increase the illinois tax and certain situations and we can prove that if you want the chance  dollars then under the new estate tax which was this whole pick up tax that we were doing here and the statute refers to the full credit calculable the attorney general's office would have you believe that that just means you take the tax applied to the table that is not what happens as never been what happens the situation is much more complicated than that with applying credits st of all you do that st calculation but that's only step number one step number two is you compare that to the federal tax and number three the and that is again what we want to show with our kids the business bit of practice all along i know my time is grieve there was one other specific point it's very