good morning morning my name is gretchen and repin i represent the city of waukegan in this appeal the city's position is simple our position is that the property is demolition stance you and when the legislature passed the two thousand amendments they got rid of that language restricting the term to the demolition statute they struck that out of the statutes of the current statute that the city is arguing under that it was in effect at the time the tax appeal was the tax objection was brought there's no longer contains that language regarding municipal code so this would just sort of history and subsequent amendments help people for whom i believe the subsequent amendments do help the city's position in that the subsequent amendments continue to broaden the statue making it after a couple two more situations i do want to clarify something that was kind of raised in the briefs in that it appears the county thinks that the city is trying to qualify their position based on the new the attention of the court that the legislature is expanding this statute to encompass more situations specifically the new amendment dealt with a situation involving a developer going bankrupt not what we're trying to do here we're not seeking to impose additional terms main purpose the primary objection objective of a court should be to give effect to the intent of the legislature and that believe there is a clear legislative intent because the term is somewhat ambiguous because the legislature did not define the term judicial deed nowhere in the case law and nowhere in any stat is there a definition that says it's a deed that has to be signed by a judge in effect under the foreclosure statute which talks about a deed similar situation is what we have with the foreclosure case  i have racked my brain out of this with all due respect and i have not been able to find anything in other jurisdictions elsewhere than defines what a judicial didas in your reply brief at the very end if you're coming to the summary you see the determining factor in the city's argument is not that it received title to the subject property as a result of the bankruptcy judges order and then you have an a and and that the twenty ten amendment of section twenty ninety five mentions bankruptcy i mean what you're saying now is that as a result of the approval of this bankruptcy judge worked in the proceedings you received it so the statement what do you mean by that statement and my position to cities position is it's not her argument that because the case was a bankruptcy is why it should be tax exempt argument is because the court authorized it it was a bankruptcy judge the judge signed the order not the deed that's true but it was court authorized without the court's approval this never would have happened and that's our position it was a judicially authorized act a judicial deed in a sense rather than the judge signing it it was a trustee in bankruptcy the sign there but nonetheless it only came about because the court authorized it so in essence your position one with the taxes just cover when the original agreement was entered into is the reason i don't believe so we have never seen any sort of tax bills we were not necessarily involved in death in the bankruptcy case and we didn't come to find out about the tax bills till two thousand and eight when we were soaked i mean you have to be of an assumption then private company can remember the name of the original owner but they would have been taxed was there ever any inquiry into what was going to happen to those back to texas i don't believe so but during the course of the negotiation were and the city was able to resolve the issues of the two thousand three hundred or two thousand four hundred six taxes or something of that nature they how it was done under a separate filing i believe and i apologize but i believe my partner could speak more to those factual situations because he was involved and it factually firsthand i kind of picked up the case later so i apologize so the only issues here are what the two thousand and one and two thousand to texas two thousand and two thousand and one and two thousand and two i believe it's three years financially have gotten this property anyway not necessarily the city not necessarily would have taken title to the property and certainly the city would have been the one stuck with making sure it was safe and secure this property was a huge nuisance it created a lot of safety concerns and nobody was stepping up to take this property and it contained a large office building manufacturing plant all of which would have gone on secure the e p a only would have concerned itself with the containment cells leaving all that other you know structures that abandoned so the city situations that were not in place prior to two thousand and ten doesn't the trustee in this case actually take the place of california or we're in terms of disposition of the property putting it in that sort of a situation where it is an agreement between the owner and the city i'm not sure of an interest in your question just if you're if you're saying it is the  bankruptcy trustee and the open sea working in the agreement together well you know the obviously the trustees taken over all or the seeds agreements but the issue is in the twenty temperature there's a developer agreement with someone or some entity well don't we have something very similar here i do agree with after the two thousand and ten version absolutely not and that's another reason why we believe even more that the appropriate two thousand and ten person we can expand upon the plain language of the statute written for for policy reasons just as counsel said that the with any specific or prior interpretation of the clear language but that is of course directly against the basic tenets of property tax looking at the language of the statute perhaps we are able to carry out the the policy reasons but we don't think that there is a beauty in the language of the statute how you respond to your position exalts form over substance to respond to the article form over substance i would say that we look at the language of the property tax code and we don't we don't broaden the language of the property tax code when we are not authorized to do sell the treasurer as a ministerial officer is not able to use his agreement that was a decision of treasure it even more narrow and because if i understand correctly your interpretation used it must be a document that says deed on the top and a judge's signature on the bottom and my question is where do you get the authority to  position as some of the making something traditionally authorized so that's our position it may be more in their role then than than the city would provide but again we don't feel that we have the authority to rule on something especially when we're talking about taxing to i cannot write so if we do we agree that a bankruptcy proceedings is a judicial proceedings correct and but but we can't agree that in order work that out during the bankruptcy proceeding again this is this is not about in our opinion equity this is not this is about the clear language of section twenty one ninety five of the code and i know urge you to affirm the order of the circuit court  paragraph seventeen on page ten why he had previously obtained tax exempt status for the subject property for those three years two thousand and three two thousand and four and two thousand and five pursuits the property tax code the dee that waukegan received were dated two thousand and two and pursuant to the property tax code we were able to go back three years and work with the county in get those taxes exempt so that's what happened with  must the city stepped up and took title nobody else was going to take title the trustee had abandoned this property the court would allow that unless the city stepped up and took over this property there was going to be huge safety concerns and there really wasn't a concern at that point about the taxes because like i said there was no money form c had no money they were in bankruptcy and that's probably why there was no agreement or concern about the taxes that were now in court about if we saw a tax bill today for this property it would be paid to the county that in the county would be paying back money to the city market getting to school districts within in that particular area and i'm not asking you to tell me what percentage but essentially it's one of it's it's almost an on paper transaction although there are some o