pay the tax bill regarding the st one this case involves the next question of attack scares and tie them into an exemption the question is there or subject to the clear that's correct your honor however there are mean that there should be no japanese zero simply because each tribe you know is not engaged in day to day ministration but if we look to the reasons why reports sites and agencies administrat has a reason for doubt prince it is because through that administration they gain expertise here however is not necessarily for the tribunals to engage in day to day str because it is statutorily mandated to happen expertise so in other words there are avenues for gaining expertise and certainly and ministration of the statute is one after taking expertise in our case air standards in these questions for the tribunal because to do otherwise and to not a court apparatus would create a few track system or two tracks a precedent whereby the department of revenues decision but moving the on the janitor review and we think it's important to emphasize that this work need not necessarily reach the proper standard review in this case because under any standard of review  carbon dioxide to produce at this stage gas product carbon monoxide so i want to be clear here that this is not simply a matter of heating hold if the chemical simply had to be heated that would potentially  closer question heating alone is not all that is required for there is an additional intermediate step in addition to heating of the carbon dioxide or excuse me the carbon combining with carbon simply the well let me just answer your question that those terms mean as the tribunal found at once without intervening factors or intermediates now it's true the tribunals books a dictionary that freezes a distinct chemical that qualifies at that point were warning the exemption which we know from illinois law we have to construe exemptions nearly so if i could buy a chemical that carbon added and carbon dioxide in each individual you were reacting with the iron and the zinc oxide i think that would qualify but if you're that's not what's going on the carbon and carbon dioxide combine to form a the council described coke as a catalyst but doesn't get used up in the process at the very end his son does it so really what what does it do beat a will question should be resolved in favor of station so this is a case of plain language statutory interpretation but in addition to that we have the construction rule or taxation legislative history on this but from reading cases from other states there is cases in states where they will not simply to the last stat as here but allow for a broader exemption or materials used in the chain achieve procedures so legislatures can make that determination that we would like to have a ward exemption that includes chemicals that are merely part of the process or part of the chain which is the some states allow that to be part of the exemption but when there is a statute that requires a direct and immediate change that is not what is contemplated there is not an allowance for a chain of reactions which is what horsehead runs out but i don't believe there's been any mention yet with respect to the abatement of the penalties thank you yes and i know that the appellate court would say that they are posing counsel allow for intermediate so the interpretations at the threshold is unreasonable they said that force had presented no evidence to support its on the reasonable inference  can you know they have to know before they even go in to apply so there's no hearing on it like you had while your honor we would say that they did cite the lack of precedent as a reason for the basement and all teams we would urge this court not to have a rule example that's used in the regulation that sounds like a direct immediate change with nothing happening other than one cut from a hole interacting with another right that  to say well i have to be something more it is just use somewhere in the process but i don't think that it was designed to draw these sorts of distinctions between well it has to be heated in that