taxes on any square footage that would be added after a specific date of july first two thousand and seven september twenty eight mark with two thousand and six began construction but it wasn't until consider the objections being brought by the college or whether such objections to the taxes that marcus would pay for the years oh nine ten and eleven we need to be brought through a tax objection proceeding and that's curious diction to decide that question and we submit that the answer to the certify question is the circuit court does not have such general jurisdiction and why does not have such a general jurisdiction we start unfortunately with what appears to be a law school action and we've seen this that the courts in our state have general jurisdiction over all this will matter our constitution tells us that however they had general jurisdiction maybe controlled are limited by statute and we learn remedy for all claims with respect to those taxes assessments or levies exception only matters which are exclusive remedies provided elsewhere those exceptions are not applicable what is specifically a political here is the limitation appellant marcus energy and we have the apple league which happens to be the college district as the court points out it is not a taxpayer the polish district but it's here today it brought a lawsuit in the circuit court what does that moreover the legislative history which is cited by the college is instructive the college seeks to urge the court to find a person and taxpayer to mean the same thing but it doesn't if we look at the legislative history the legislative history put on marcus energy and i think that's the difference between your example and what is posed by this case in this case there are a person objecting to the amount of taxes being paid and they are claiming an injury because they're not getting and i don't think they're doing it just because they're the proverbial nice citizens they want to help someone else get more no but it's ok so when we look at this if you will and i think context the context is the complaint  they're doing is they're taking outside of the tax code the property tax exclusive remedy and they're saying let's have the circuit or have the whole jurisdiction go forward and that brings us to our next problem the equitable jurisdiction in the circumstances that we have in this kind of case the taxpayer is still responsible for the taxes there is no question that whether a tax of the action is filed or is not filed at the taxpayer remains responsible until the limited specifically by the ads and by doing so you step away from saying you can hear everything you say you can only hear certain things but not this and there's a complete lemon in the tax code they could go that route now by way of just simply more if you will context there are also proceedings in front of the property thank you for their ongoing so the question i think that we're really left with is what is that sort of like question how can you answer i would submit to the board the question the negative that it does not and therefore the college should be left to its remedy that it has the property tax code whatever that may be but we have a question you know yes the only question is is that we're saying in  the county clerk in lease their positions the county clerk did not correctly apply the abatement ordinance or the people tried to buy the tax industry the property tax affection procedure only ok but then let's put this all in the big picture context down springfield when they came up with this legislation what they're really saying this is a specialized area ok we've got i mean the property tax in eleanor's is a labyrinth of arcane not understandable no home or a stance of this you know i know most time they do it only because they're their neighbors not paying enough  taken in a very narrow view you may be correct however taken out of the entire property tax structure i think it does prompt wrong on the property tax code and the reason i think it was there put this problem hopes in some a lawyer decide them quickly or more quickly than might otherwise be the case and therefore get the right amount of taxes either given back to the taxpayer is too much or to pay more if it's too much so i think that it be pleased the court morning with the two themes i would like to leave with the court this morning number one the horror of this case is the resolution adopted by the college and the actions of the clerk in not following his ministerial duty to get here to that under the enterprise zone act point number two for counsel is very skilled to be successful in this matter he must succeed on all of his points that he is it raining or work and if you fails to do so if he doesn't we don't all that is argument should fall looking first at the concert we have regarding the clerk's ministerial duty and therefore the subject managers diction that that the we believe the trial or have the to distinguish the village a park forest case the county and will case and the village of inverness case however those cases were all decided under predecessor statutes to the  property tax code specifically in the village of park horace to case that if they were underage the comparable section two hundred twenty three dash five which is one of the sections at issue here and that statute from nine hundred fifty five indicated there any person shall desire to object they shall pay all or part of the real property taxes for europe for any reason so there has been a longstanding statutory obligation or a tax payer person from the perspective of of counsel if they're going to go forward with tax objection to have to file taxes as it relates to them so having looked at that in the current statute and twenty five and having looked at the prior statute then we cited a number of cases to the court not all of which are going to bring to your attention this one of the thumb of them which i think we should highlight we mentioned that village of park forest case which was in the illinois supreme court case from one nine hundred fifty eight and in that case mandamus was proper remedy to enforce the performance of statutory duties we would suggest the clerk has a statutory duty to follow our resolution because without a resolution under the enterprise on the act he wouldn't have any authority to act and so his failure to act was inconsistent his actions were inconsistent with his duty in that case the village of the tax payer filed a petition for writ of mandamus you know number two i would they failed to assess certain properties within its decision books before closure that obviously would have affected assessments so it picks the statutes and the predecessor sta reorganized was contesting bonded indebtedness and sued for mandamus and the court concluded that mandamus was appropriate in that circumstance despite article twenty three obviously having an interest owed on a refund but it was that land tax bill oh yes ok ok and lastly the two thousand and eleven illinois supreme court case the auburn case which we made reference to you which also was decided after the madison case made reference to by council where the board of education in the school district again biol against the department of revenue seeking declaratory judgment that pete telling the logger applied to the district pretty organized and now had some land in the county that was not under p tell of the supreme court granted the declaratory judgment in that situation council also talks about that since we've been talking about the madison case mentions that and so we would suggest as we mentioned in the maxims cited in our brief that statutes should be construed in a manner so that no term is rendered meaningless or superb lutes counsel is focusing on the term person there and we would argue that yes the madison case is distinguishable and applicable to this situation for several reasons number one in the madison case the taxing district was seeking permission to intervene as opposed to being a petitioner that's what the court was looking at in that case the  the next objection had already been filed in that particular case so the very distinguishable from our situation secondly the reference to person in that case it's been taking in one sen which counsel extends to our means that we have an obligation as a tax in district as opposed to a right to intervene in an obligation to be a petition or in a tax objection matter and there is no indication in that case that it was briefed that point was very there's no indication that that was are in that case the people versus williams case indicated that since the issue was brief and was argued by the parties in court pronouncement was conditional that in the williams case but there's no evidence in our case that was the matter and to the extent that this is a seminal point from the court's perspective then we would strongly urge the court to read the nine  continuing on then we also brought to the court's attention the cases after madison which we mentioned to you a little bit ago that we believe indicate that madison does not stand for the proposition that the taxing district has an interpretations of statutes or disfavor apologized the first so i did if you was with the burger case the second one was people versus ingram and lastly or is presumed that the legislature did not inten this as you are suggesting before a justice would not be a party to this matter by virtue of what he fifteen next the taxing district would not be provided interest on the money that it had  objection map but no comparable language is in there regarding the taxing districts so theoretically the tax in the district that's correct would be able to pile simultaneously which would not be appropriate for i'd also point out that there are several other provisions within the property tax code where the term taxi district and person arkan's pain in the same section and therefore the general assembly must out under certain circumstances intended that the term person would not necessarily apply to a taxing district and we would suggest that is our situation as well so in conclusion as i said before accomplice when on all of it his points or fall he must prove that it was the intent of of the statute that the taxing district come under article twenty three  he doesn't win on the suggestion of the definition of person in addition to tax and in in addition to intent he loses if he can't prove it is not an authorized by law he loses tax money and not get back in it's constitutional for us not to get paid interest on what we're doing in firing that i would suggest that the decision of the trial court below be affirmed the trial this very same resolution contrary to what counsel is saying this is an ongoing matter that started in two thousand and ten with assessments and a resolution in two thousand and eight and has been going affected they get notice secondly why are those your role they're relevant as we discussed there would be no need for the taxing district to pay because the taxpayer still would have the obligation and we're not talking about having to be a lesser you question about interest or about refunding taxes that's a remedy that would exist and in the process and once again it's not the specific bill if you will finally with respect to these issues there are a number of limited the general applicable jurisdiction of the trial or to decide objections by a person with tax for any reason and that is precisely what the plate and the amended complaint from this matters to you as a