2022 IL 126929 

IN THE 

SUPREME COURT 

OF 

THE STATE OF ILLINOIS 

(Docket No. 126929) 

In re APPLICATION OF THE COUNTY COLLECTOR, for Judgment and 

Order of Sale Against Lands and Lots Returned Delinquent for 

Nonpayment of General Taxes for the Year 2014 and 

Prior Years (Blossom63 Enterprises, LLC, Appellee, 

v. Devonshire, LLC, Appellant). 

Opinion filed March 24, 2022. 

JUSTICE NEVILLE delivered the judgment of the court, with opinion. 

Chief Justice Anne M. Burke and Justices Garman, Theis, Michael J. Burke, 

Overstreet, and Carter concurred in the judgment and opinion. 

OPINION 

¶ 1 On February 15, 2018, GAN C, LLC (GAN C), filed a petition for a tax deed 

to acquire property it purchased at Cook County’s 2016 annual tax sale for the tax 

year 2014. On April 24, 2018, GAN C assigned its interest in the property to 
 

 

 

 

 

Blossom63 Enterprises, LLC (Blossom63). On May 6, 2018, 6420 Longmeadow 

LLC, the owner of the property, transferred its interest in the property to 

Devonshire, LLC (Devonshire). On May 17, 2018, Devonshire filed a petition to 

intervene in the tax deed proceedings and moved to vacate Blossom63’s tax deed 

on the ground Blossom63 failed to strictly comply with the notice requirements of 

the Property Tax Code (Tax Code). 35 ILCS 200/22-5, 22-10 (West 2016). On May 

18, 2018, the circuit court of Cook County granted the petition for a tax deed, and 

the county clerk for Cook County issued Blossom63 a tax deed to the subject 

property. On June 19, 2019, the circuit court granted Devonshire’s motion to vacate 

the order issuing a tax deed to Blossom63. The appellate court reversed, finding 

Blossom63’s notice strictly complied with section 22-5 of the Tax Code. See 2020 

IL App (1st) 191464, ¶ 29. On March 24, 2021, we allowed Blossom63’s petition 

for leave to appeal (Ill. S. Ct. R. 315 (eff. Oct. 1, 2020)) and now affirm the 

judgment of the appellate court. 

¶ 2 I. BACKGROUND 

¶ 3 On June 3, 2016, GAN C purchased the delinquent property taxes on “Unit A” 

in a commercial condominium building in Lincolnwood at Cook County’s annual 

tax sale for the tax year 2014. At the time of the tax sale, 6420 Longmeadow LLC 

owned the property. GAN C also paid the second installment on the 2013 property 

taxes on the condominium to complete the sale. See 35 ILCS 200/21-240 (West 

2016). Section 21-240 of the Tax Code requires a purchaser at an annual tax sale 

(1) to pay, “forthwith,” the taxes, special assessments, interest and costs advertised 

for the tax sale and (2) to pay, “within 10 days after the sale,” the general taxes 

charged on the land remaining due and unpaid not included in the advertisement. 

Id. When payment is made, the “purchaser then shall be entitled to a certificate of 

purchase.” Id. 

¶ 4 On September 16, 2016, the county clerk for Cook County issued a certificate 

of purchase to GAN C for the property pursuant to section 21-250 of the Tax Code. 

See id. § 21-250. The certificate of purchase states GAN C purchased the property 

for the taxes, interest, and costs due and unpaid for the tax year 2014 and that it 

paid as purchase money on the property the total amount of taxes, interest, and 

costs. The certificate of purchase states GAN C paid $40,300.02 in general tax for 

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2014 and $6762.55 in general taxes for the 2013 second installment plus fees, for a 

total of $47,309.57. 

¶ 5 On September 27, 2016, GAN C delivered a notice of sale form, pursuant to 

section 22-5 of the Tax Code (the notice of sale form provision), to the county clerk 

for Cook County for delivery. See id. § 22-5. Section 22-5 provides that to be 

entitled to a tax deed, “within 4 months and 15 days after any sale held under this 

Code, the purchaser or his or her assignee shall deliver to the county clerk a notice 

to be given to the party in whose name the taxes are last assessed.” Id. GAN C’s 

section 22-5 notice of sale form, on the line “Sold for General Taxes of (year),” 

read “Sold for General Taxes of 2014.”1 The section 22-5 notice of sale form listed 

March 29, 2017, as the date the period to redeem the property would expire and 

listed $47,340.01 as the amount needed to redeem the property. 

¶ 6 On April 11, 2017, GAN C filed a notice, pursuant to section 22-10 (the notice 

of expiration of period of redemption form), with the county clerk for Cook County. 

See id. § 22-10.2 Section 22-10 provides that 

“[a] purchaser or assignee shall not be entitled to a tax deed to the property sold 

unless, not less than 3 months nor more than 6 months prior to the expiration of 

the period of redemption, he or she gives notice of the sale and the date of 

expiration of the period of redemption to the owners, occupants, and parties 

interested in the property.” Id. 

GAN C’s section 22-10 notice of expiration of period of redemption form, on the 

line “Sold for General Taxes of (Year),” read “2014 (2013 Incld).” See Appendix 

II, infra ¶ 56. The section 22-10 notice of expiration of period of redemption form 

stated the period of redemption would expire on September 13, 2017. 

1

The section 22-5 notice of sale form notice is attached to this opinion and will be referred to 

as Appendix I. See Appendix I, infra ¶ 55. 2

The section 22-10 notice of sale form notice is attached to this opinion and will be referred to 

as Appendix II. See Appendix II, infra ¶ 56. 

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¶ 7 A. Circuit Court 

¶ 8 On February 15, 2018, GAN C filed an application in the circuit court of Cook 

County for an order directing the county clerk to issue a tax deed. GAN C attached 

copies of its certificate of purchase, the section 22-5 notice of sale form, and the 

section 22-10 notice of expiration of period of redemption form to the application. 

¶ 9 On April 24, 2018, GAN C assigned its rights and interest in the certificate of 

purchase to Blossom63. On May 6, 2018, 6420 Longmeadow LLC transferred its 

property to Devonshire by warranty deed. On May 17, 2018, Devonshire moved to 

intervene in the tax sale proceedings, and the circuit court granted its motion. On 

May 18, 2018, the circuit court entered an order to issue a tax deed to the property 

to Blossom63. Blossom63 recorded the tax deed to the property. 

¶ 10 On June 14, 2018, Devonshire moved, pursuant to section 2-1203 of the Code 

of Civil Procedure (735 ILCS 5/2-1203 (West 2018)), to vacate the order issuing a 

tax deed to Blossom63 on the ground the section 22-5 and 22-10 notices failed to 

strictly comply with the Tax Code. On March 18, 2019, the circuit court granted 

Devonshire’s motion to vacate on the ground Blossom63 failed to strictly comply 

with the notice requirement in section 22-5 of the Tax Code by listing only 2014 as 

the tax year sold without including the 2013 second installment taxes. The circuit 

court entered an order vacating Blossom63’s tax deed and ordering Devonshire to 

pay interest on the amount it owed Blossom63 pursuant to section 22-80 of the Tax 

Code. See 35 ILCS 200/22-80 (West 2016). Section 22-80 of the Tax Code requires 

a party who is successful in a challenge to an order to issue a tax deed to pay the 

tax deed grantee, or his or her successors and assigns (or, if a tax deed has not yet 

issued, the holder of the certificate), within 90 days after the date of the finding, the 

amounts delineated in section 22-80(b). See id. § 22-80(b). The parties disagreed 

on the amount of interest Devonshire had to pay to Blossom63. The circuit court 

agreed with Devonshire on the amount of interest it had to pay Blossom63 and 

ordered the funds deposited with the clerk of the circuit court pending appeal. 

Blossom63 appealed the circuit court’s order vacating the judgment directing the 

county clerk to issue a tax deed. 

¶ 11 B. Appellate Court 

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¶ 12 A divided panel of the appellate court found that the parties conceded that the 

Tax Code requires strict compliance with the section 22-5 notice requirements. 

2020 IL App (1st) 191464, ¶¶ 19, 22; 35 ILCS 200/22-40(a) (West 2016). In the 

appellate court, Devonshire argued that (1) section 21-240 of the Tax Code required 

Blossom63 to pay the 2014 taxes and the outstanding second installment of the 

2013 taxes to complete the sale and (2) the 2013 taxes were part of the tax sale and 

Blossom63 was required to list both the 2014 and 2013 taxes on Blossom63’s 

section 22-5 notice of sale form. See 2020 IL App (1st) 191464, ¶ 25. 

¶ 13 The appellate court found that the purpose of the first part of the section 22-5 

notice of sale form requiring the tax purchaser to list the year of the property taxes 

purchased at the sale (“ ‘Sold for General Taxes of (year)’ ”) is to inform the 

property owner of the sale for delinquent taxes and specifically “requires the 

[purchaser] to list the tax year sold—2014, in this case.” Id. ¶ 26. The appellate 

court found that the second part of the section 22-5 notice of sale form serves a 

different purpose: to advise the property owner of the need to redeem the property 

to avoid losing title and to inform the owner that the property will go to tax deed 

unless redeemed by a specified date for a specified sum of money. Id. ¶ 29. The 

appellate court held Blossom63 satisfied the purpose of the first part of the notice 

of sale form by listing 2014 as the tax year sold “as required by the form” without 

also listing prior years that had to be paid. Id. ¶ 27. 

¶ 14 The appellate court also found that a completely separate section of the Tax 

Code, section 21-240, provides that the purchaser must pay all prior unpaid taxes 

to obtain a certificate of purchase. Id. ¶ 26. The appellate court held that 

“Blossom63 was required to pay the unpaid 2013 second installment to complete 

the 2014 tax sale purchase, but it did not purchase the 2013 taxes at the 2014 tax 

sale. So Blossom63 complied with the requirement that it list ‘Sold for General 

Taxes of (year)’ by listing 2014 only.” (Emphases added.) Id. The court also held 

Blossom63 satisfied the purpose of the second part of the section 22-5 notice of 

sale form by “informing Devonshire that, by a specified date, it must pay 

$47,309.57, which includes both the 2014 and 2013 taxes,” because that was the 

“information necessary to avoid the owner losing the property.” Id. ¶ 29. 

¶ 15 The dissenting justice found that “[t]he use of ‘(year)’ on the [section 22-5 

notice of sale form] *** refers to the ‘year or years’ for which the purchaser paid 

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the taxes.” Id. ¶ 37 (Walker, P.J., dissenting). The dissent concluded that 

Blossom63’s section 22-5 notice of sale form incorrectly represented that the 

collector sold the property for the 2014 taxes. According to the dissent, because the 

purchaser actually paid the 2014 and 2013 taxes, the section 22-5 notice of sale 

form did not strictly comply with the Tax Code. Id. 

¶ 16 The parties also disagreed as to the amount Devonshire was required to pay 

Blossom63 pursuant to section 22-80. However, in light of its disposition, the 

appellate court found that Blossom63 prevailed on its tax purchase, no sale in error 

was declared, and Blossom63 was not entitled to any reimbursement under section 

22-80. See id. ¶ 31 (majority opinion). 

¶ 17 II. ANALYSIS 

¶ 18 A. The Standard of Review 

¶ 19 The issue in this case—the tax year required on the “Sold for General Taxes of 

(year)” line of the section 22-5 notice of sale form—presents a question of statutory 

construction. See In re Application of Skidmore, 2018 IL App (2d) 170369, ¶ 10 

(finding the question of whether using a property index number (PIN) as the 

certificate of sale number required by the section 22-5 notice of sale form strictly 

complied with section 22-5 of the Tax Code to be a question of statutory 

construction). The primary goal of statutory construction is to ascertain and give 

effect to the intent of the legislature. In re Application of the County Treasurer, 214 

Ill. 2d 253, 258 (2005) (Dwyer). The best evidence of legislative intent is the 

language of the statute, which should be given its plain and ordinary meaning. 

Lakewood Nursing & Rehabilitation Center, LLC v. Department of Public Health, 

2019 IL 124019, ¶ 17. Because the statute is viewed as a whole, words and phrases 

must be construed in light of other relevant statutory provisions and not in isolation. 

Pooh-Bah Enterprises, Inc. v. County of Cook, 232 Ill. 2d 463, 493 (2009). Each 

word, clause, and sentence of a statute must be given a reasonable meaning, if 

possible, and should not be rendered superfluous. A.P. Properties, Inc. v. 

Goshinsky, 186 Ill. 2d 524, 532 (1999). In determining legislative intent, a court 

may consider not only the language of the statute but also the reason and necessity 

for the law, the problems sought to be remedied, the purpose to be achieved, and 

the consequences of construing the statute one way or another. Oswald v. Hamer, 

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2018 IL 122203, ¶ 10. Further, we must presume that the legislature did not intend 

to enact a statute that leads to absurdity, inconvenience, or injustice. Dwyer, 214 

Ill. 2d at 259. When an issue requires this court to construe or interpret the relevant 

statute, we conduct that review de novo. In re Application for a Tax Deed, 2021 IL 

126150, ¶ 17. 

¶ 20 B. General Tax Sale Procedures 

¶ 21 1. Relevant Procedures Before the Sale 

¶ 22 The sale of property for taxes is governed by article IX, section 8(a), of the 

Illinois Constitution. Ill. Const. 1970, art. IX, § 8(a). After taxes become delinquent 

in any year, the county collector begins by publishing an advertisement of a list of 

delinquent properties. 35 ILCS 200/21-110 (West 2016); Jeffrey S. Blumenthal & 

David R. Gray Jr., Tax Bills and Payments; Tax Sales and Redemptions; 

Miscellaneous Collection and Enforcement Matters, Real Estate Taxation: 

Assessments, Rate Challenges, and Tax Sale Matters § 6.21 (Ill. Inst. for 

Continuing Legal Educ. 2020) (hereinafter IICLE § 6.21). Section 21-110 of the 

Tax Code provides: “At any time after all taxes have become delinquent in any 

year, the Collector shall publish an advertisement, giving notice of the intended 

application for judgment and sale of the delinquent properties.” (Emphasis added.) 

35 ILCS 200/21-110 (West 2016). The advertisement of the list of delinquent 

properties serves as the process by which the court acquires jurisdiction over the 

properties. People ex rel. Brenza v. Anderson, 411 Ill. 252, 255 (1952) (“The record 

of delinquent property required by section 232 of the act serves as a declaration or 

complaint in the proceedings to obtain judgment for delinquent taxes, while the 

published notice serves as process.”); see also IICLE § 6.21. 

¶ 23 2. Relevant Procedures at the Sale 

¶ 24 At the “sale of property for taxes,” the collector shall “proceed to offer for sale 

*** all property in the list on which the taxes, special assessments, interest or costs 

have not been paid.” 35 ILCS 200/21-205(a) (West 2016). “The sale shall not be 

closed until payment is made or the property again offered for sale.” Id. § 21-240. 

In Cook County, where the property at issue in this case is located, the purchaser at 

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a tax sale is only required to pay the taxes, special assessments, interest, and costs 

as advertised in the sale “forthwith.” Id. However, the purchaser may also be 

required to pay the “general taxes *** remaining due and unpaid *** not included 

in the advertisement, *** within 10 days after the sale” or after receipt of a 

statement of back taxes. Id. Once the aforementioned payments are made the 

purchaser is “entitled to a certificate of purchase.” Id. A certificate of purchase and 

the notices required by law are required for a purchaser to receive a tax deed to the 

property. See id. § 22-40(a) (section 22-40 provides the circuit court shall enter an 

order directing the county clerk to issue a tax deed “on the production of the 

certificate of purchase and a certified copy of the order”). 

¶ 25 3. Relevant Procedures After the Sale 

¶ 26 The owner or any person interested in the property sold at the tax sale has a 

right to redeem the property (id. § 21-345) for a specified period of time (id. § 21-

350) by paying the amounts delineated by section 21-355 to the county clerk (id. 

§ 21-355) in order to obtain a release of the purchaser’s claim to the property by 

virtue of purchase, withdrawal, or forfeiture (id. § 21-390). The purchaser, or his or 

her assignee, may file a petition asking the circuit court to issue a tax deed for the 

property if the property is not redeemed. Id. § 22-30. To be entitled to a tax deed, 

the purchaser or assignee must also, within 4 months and 15 days after the tax sale, 

provide the county clerk with a notice of sale form to be given to the party in whose 

name the taxes were last assessed. Id. § 22-5 (section 22-5 notice). Section 22-5 of 

the Tax Code prescribes the form of the section 22-5 notice of sale form. See 

Appendix I, infra, ¶ 55. 

¶ 27 The purchaser or assignee is not entitled to a tax deed unless the purchaser or 

assignee also sends the notice referenced in section 22-10 not less than three months 

nor more than six months prior to the expiration of the redemption period and gives 

notice of the sale and the date of expiration of the period of redemption to the 

owners, occupants, and parties interested in the property. 35 ILCS 200/22-10 (West 

2016). 

¶ 28 The judgment in a tax deed case is subject to attack as any other judgment in a 

nonjury case. Dwyer, 214 Ill. 2d at 270 (“the statute permits a direct attack, by 

postjudgment motion, pursuant to section 2-1203 of the Code of Civil Procedure” 

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(735 ILCS 5/2-1203 (West 2000))). If a challenge to the entry of a judgment 

directing the county clerk to issue a tax deed is successful, then the court’s finding 

and order vacating the judgment ordering the clerk to issue a tax deed must also 

direct the party who successfully challenged that judgment to pay the tax deed 

grantee, or his or her successors and assigns (or, if a tax deed has not yet issued, the 

holder of the certificate), within 90 days after the finding the amounts listed in 

section 22-80(b) of the Tax Code. 35 ILCS 200/22-80(b) (West 2016). 

¶ 29 C. The Section 22-5 Notice of Sale Form 

¶ 30 Initially, we note that the purpose to be achieved by the section 22-5 notice of 

sale form is to protect property owners from losing their property in a tax sale, not 

to assist tax purchasers to obtain properties with delinquent taxes. See id. § 22-5; 

see also In re Application of Rosewell, 127 Ill. 2d 404, 409 (1989) (“In interpreting 

a statute that enforces a tax lien by selling the taxpayer’s property, the general 

policy is to favor the property owner’s rights.”); In re Application of County 

Treasurer & ex officio County Collector, 2011 IL App (1st) 101966, ¶¶ 27-35 

(Glohry) (conducting “a thorough review of the legislative history of [the notice] 

provisions” in the Tax Code). In Glohry, the appellate court concluded that “it is 

clear that the legislature’s goal was to provide all necessary information to the 

owner to assist and encourage a tax assessee to redeem his property.” Glohry, 2011 

IL App (1st) 101966, ¶ 32. Based on the plain language of section 22-5 (the notice 

of sale form provision), the notice serves four purposes: to provide the property 

owner with (1) information pertaining to the fact of the sale, (2) the date when the 

period of redemption will expire, (3) the information that a petition for a tax deed 

will be filed if the property is not redeemed by a certain date, and (4) the total 

amount needed to redeem. 35 ILCS 200/22-5 (West 2016); see also In re 

Application of the County Collector, 225 Ill. 2d 208, 212 (2007) (Lowe). 

¶ 31 This court has held that a petitioner for a tax deed must demonstrate strict 

compliance with the notice requirements in the Tax Code. Clark v. Zaleski, 253 Ill. 

63, 74 (1911); Skidmore, 2018 IL App (2d) 170369, ¶ 10. Tax deed petitioners are 

required to use the form notice set forth in section 22-5 of the Tax Code, and the 

plain language of the statute requires that the section 22-5 notice of sale form must 

be “ ‘completely filled in.’ ” See Skidmore, 2018 IL App (2d) 170369, ¶ 10 (quoting 

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35 ILCS 200/22-5, 22-10 (West 2016)); Appendix I, infra ¶ 55. Therefore, we agree 

with the appellate court that, where the section 22-5 notice of sale form is complete 

and the information therein is accurate, strict compliance with section 22-5 has been 

shown. Compare 2020 IL App (1st) 191464, ¶ 23 (the purchaser complied with 

section 22-5), with Gaither v. Lager, 2 Ill. 2d 293, 303 (1954) (the purchaser failed 

to comply with the conditions of the act). 

¶ 32 D. The Parties’ Arguments 

¶ 33 The issue Devonshire raises in its brief is whether section 22-5 of the Tax Code 

requires all delinquent tax years “included in the sale” to be listed on the section 

22-5 notice of sale form. See Appendix I, infra ¶ 55. Devonshire maintains that 

Blossom63 failed to strictly comply with section 22-5 of the Tax Code when it 

failed to list both the 2014 and 2013 taxes on its section 22-5 notice of sale form. 

See Appendix I, infra ¶ 55. Devonshire maintains that section 22-5 requires specific 

information regarding the years of general taxes paid by the purchaser at the tax 

sale and in support notes that section 21-240 of the Tax Code requires full payment 

of all delinquent taxes—in this case for tax year 2014 and partial tax year 2013— 

to complete the purchase and entitle the purchaser to a certificate of purchase. 

Devonshire also cites Gage v. Davis, 129 Ill. 236 (1889) (per curiam), and Gaither, 

2 Ill. 2d 293, in support of its position that the section 22-5 notice of sale form is 

intended to provide information regarding the actual years of taxes paid at the tax 

sale and not simply the year of the delinquent taxes purchased at the sale. 

¶ 34 Blossom63 disagrees and maintains that, because a delinquent property may be 

subject to multiple tax sales for separate tax years, including for taxes that accrue 

after the sale, the purpose of the section 22-5 notice of sale form is to notify the last 

taxpayer (1) which tax sale to request an estimate of redemption for and (2) which 

tax sale year to redeem. Blossom63 maintains that the estimate of redemption, not 

the section 22-5 “Take Notice,” serves to provide the information on all of the years 

associated with the tax sale. 

¶ 35 E. Application of Tax Sale Provisions and 

Section 22-5 to Parties’ Arguments 

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¶ 36 To resolve the first issue, we begin by analyzing the language in the statute 

requiring the purchaser to list or provide the following information—“Sold for 

General Taxes of (year)”—on the section 22-5 notice of sale form. See Mashal v. 

City of Chicago, 2012 IL 112341, ¶ 21 (in determining legislative intent, we may 

properly consider the statute’s ultimate aim). The question for this court to 

determine is what tax years the legislature intended to be recorded on the section 

22-5 notice of sale form when it directed the purchaser to list “Sold for General 

Taxes of (year)” in the section 22-5 notice of sale form. 35 ILCS 200/22-5 (West 

2016). We note that the legislature included three headings in the section 22-5 

notice of sale form (see Appendix I, infra ¶ 55), but those headings are only helpful 

if they shed light on ambiguous words or phrases. Brotherhood of R.R. Trainmen 

v. Baltimore & Ohio R.R. Co., 331 U.S. 519, 528-29 (1947) (finding that the title 

of a statute and the heading of a section of a statute are of use only when they shed 

light on some ambiguous word or phrase but cannot undo or limit that which the 

text makes plain) (cited in Michigan Avenue National Bank v. County of Cook, 191 

Ill. 2d 493, 505-06 (2000)). 

¶ 37 The notice of sale form has three headings: The first heading in the section 22-

5 notice of sale form is titled “Take Notice,” the line for “Sold for General Taxes 

of (year)” is found in the first part of the section 22-5 notice of sale form, and this 

part of the section 22-5 notice of sale form requires the purchaser, or his or her 

assignee, to list the following: 

(1) the county the property is located in, 

(2) the date the property was sold, 

(3) the certificate of purchase number, and 

(4) the year of the general taxes sold, “Sold for General Taxes of (year).” 

See 35 ILCS 200/22-5 (West 2020); Appendix I, infra ¶ 55. 

¶ 38 The second heading in the section 22-5 notice of sale form is titled “THIS 

PROPERTY HAS BEEN SOLD FOR DELINQUENT TAXES,” and the second 

part of the section 22-5 notice of sale form requires the purchaser or assignee to list 

the following: 

(1) the location of the property, 

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(2) the legal description or PIN for the property, 

(3) the date the period of redemption will expire, 

(4) that a petition for tax deed will be filed if the property is not redeemed, 

and 

(5) the total dollar amount needed to redeem the property. See 35 ILCS 

200/22-5 (West 2020); Appendix I, infra ¶ 55. 

¶ 39 The third heading in the section 22-5 notice of sale form is titled “YOU ARE 

URGED TO REDEEM IMMEDIATELY TO PREVENT LOSS OF PROPERTY,” 

and the third part of the section 22-5 notice of sale form requires the purchaser or 

assignee to list the following: 

(1) that redemption can be made at any time before (the redemption period 

expiration date) by applying to the county clerk of (Cook) County, Illinois, at 

the office of the county clerk, and 

(2) that the above amount is subject to increase at six-month intervals from 

the date of sale. See 35 ILCS 200/22-5 (West 2020); Appendix I, infra ¶ 55. 

¶ 40 This court will not construe a word, clause, or sentence of a statute or different 

sections of the statute in a way that renders any word or part superfluous. Lakewood 

Nursing & Rehabilitation Center, LLC, 2019 IL 124019, ¶ 17. We find that the 

purpose served by the first part of the 22-5 notice of sale form is to provide the 

property owner with information of the fact of the sale. All of the other information 

intended to be conveyed by the section 22-5 notice of sale form—(1) the date when 

the period of redemption will expire, (2) the information that a petition for a tax 

deed will be filed if the property is not redeemed by a certain date, and (3) the total 

amount needed to redeem—is provided in another part of the section 22-5 notice of 

sale form. See 35 ILCS 200/22-5 (West 2016); see also Lowe, 225 Ill. 2d at 212; 

Appendix I, infra ¶ 55. 

¶ 41 We agree with the appellate court that, while the first part of the section 22-5 

notice of sale form informs the property owner that the property has been sold for 

delinquent taxes at an annual tax sale, the second part of the section 22-5 notice of 

sale form serves a different purpose: to advise the property owner that the property 

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will go to tax deed unless redeemed by a specified date for a specified sum. See 

2020 IL App (1st) 191464, ¶¶ 26, 29. Therefore, we find that the appellate court 

correctly held that the specific purpose of the “Sold for General Taxes of (year)” 

requirement is satisfied by listing the tax sale year, here 2014, of the delinquent 

taxes the purchaser acquired an interest in at the tax sale. See id. ¶ 26. 

¶ 42 Devonshire, relying on section 21-240 of the Tax Code, maintains that 

informing the property owner of all the years for which the purchaser paid 

delinquent taxes in the first part of the section 22-5 notice of sale form is necessary 

to inform the property owner of the amount it must pay to redeem the property. We 

reject Devonshire’s argument that section 22-5 requires the purchaser to list all of 

the years of delinquent general taxes paid by the purchaser at the tax sale in the first 

part of the section 22-5 notice of sale form. It should be noted that the purpose of 

section 22-5 is to provide the owner with notice of the sale and with notice of his 

or her redemption rights. 35 ILCS 200/22-5 (West 2016). While section 21-240 

provides the purchaser, or his or her assignee, with notice of the payment required 

to complete the purchase of the property at the tax sale. Id. § 21-240 (section 21-

240 of the Tax Code requires full payment of all delinquent taxes to complete the 

purchase). 

¶ 43 Article 21 of the Tax Code is titled “Due Dates, Delinquencies, and 

Enforcement of Payments.” See id. art. 21. The specific division of article 21 in 

which section 21-240 is found is titled “Annual Tax Sale Procedure.” Id. art. 21, 

div. 4. The section 22-5 notice requirement is in a different article, article 22 of the 

Tax Code, titled “Tax Deeds and Procedures.” See id. art. 22. Moreover, nothing in 

section 22-5 references section 21-240 or instructs a tax purchaser to include the 

information required by section 21-240 in the first part of the section 22-5 notice 

of sale form. We find no language in section 22-5 of the Tax Code to support 

Devonshire’s contention. Therefore, because the language in section 22-5 is clear, 

we cannot give the statute the construction proffered by Devonshire. See In re 

Marriage of Dahm-Schell, 2021 IL 126802, ¶ 35. 

¶ 44 We hold that the appellate court correctly held that Blossom63 satisfied the 

requirements of the first part of the section 22-5 notice of sale form by listing 2014 

as the tax year sold without also listing the prior years of delinquent taxes it paid to 

complete the sale pursuant to provisions of the Tax Code. See 2020 IL App (1st) 

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191464, ¶ 29. We also agree with the appellate court that Blossom63 satisfied the 

requirements of the remaining part of the section 22-5 notice of sale form. 

Therefore, we hold Blossom63 strictly complied with all the notice requirements of 

the Tax Code. 

¶ 45 F. The Cases Relied on by Devonshire Are Inapposite 

¶ 46 We note that Devonshire cites this court’s decisions in Gage, 129 Ill. at 239, 

and Gaither, 2 Ill. 2d at 300, in support of its position that the notice issued by the 

tax purchaser or assignee must state each tax year the purchaser paid to complete 

the sale. We find the aforementioned cases do not support Devonshire’s position. 

¶ 47 In Gage, this court found that two notices to property owners following a tax 

sale were insufficient. Gage, 129 Ill. at 239. The first was insufficient because the 

notice only stated that the property was sold for taxes and special assessments 

levied for the year 1872 but failed to inform the property owner whether the 

property was sold for a tax or for a special assessment. Id. The second notice was 

insufficient because it specified the wrong date when the period of redemption 

would terminate. Id. at 240. Gage clearly did not interpret the language in section 

22-5 requiring a tax purchaser to list “Sold for General Taxes of (year).” See id. at 

239-40; 35 ILCS 200/22-5 (West 2016). Gage only holds that notices required by 

section 216 of the revenue act, now sections 22-5 and 22-10 of the Tax Code, must 

clearly state whether the taxes involved in the sale were for general taxes or special 

assessments and must list the proper date when the period of redemption will 

terminate. Gage, 129 Ill. at 239-40; Ill. Rev. Stat. 1889, ch. 120, § 216. 

¶ 48 In Gaither, the property owner argued the notice was defective because it did 

not show for what year’s tax the land was sold and did not specify whether the sale 

was for general taxes or special assessments. Gaither, 2 Ill. 2d at 300. This court 

held the notice in that case was not sufficient to even show substantial compliance 

with the statute because the notice was “completely lacking” as to whether the sale 

had been for taxes or special assessments or for what year’s taxes or assessments 

the land was sold. Id. at 302. Although Gaither held the notice must identify what 

year’s taxes or the special assessments the land was sold for, it does not address 

whether the year for which taxes were sold means the tax sale year or all of the 

delinquent tax years the purchaser paid at the tax sale. Id. Gaither does not address 

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the issues in this case and, therefore, is inapposite. Accordingly, we find that 

Devonshire’s reliance on Gage and Gaither is misplaced. 

¶ 49 G. Remaining Arguments 

¶ 50 Based on our findings, we have no need to address Devonshire’s remaining 

arguments on appeal, including Devonshire’s arguments (1) that the amount paid 

pursuant to section 22-80 should not include interest on taxes paid by the purchaser 

for the period between the expiration of the period of redemption and the date the 

order to issue a tax deed is vacated and (2) that property, not taxes, is sold at the 

annual tax sale. A decision on either issue would not result in any relief to 

Devonshire, and “this court does not render advisory opinions or decide issues that 

would not result in appropriate relief.” See Fillmore v. Taylor, 2019 IL 122626, 

¶ 34. 

¶ 51 III. CONCLUSION 

¶ 52 In sum, we hold that Blossom63 strictly complied with section 22-5 by listing 

the delinquent tax year for which the sale was held without listing the additional 

delinquent tax years for which it paid taxes to complete the sale. Accordingly, the 

judgment of the appellate court is affirmed. 

¶ 53 Appellate court judgment affirmed. 

¶ 54 Circuit court judgment reversed. 

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~ 55 Appendix I 

6420 N LONGMEADOW LLC 1 

7225 N KOSTNHR UNIT A 

LINCOLNWOOD, IL. 60712;_·l9l9 I 

TAKE NOTICE CC-0, at. Notices 

IRIJMH4.00a!J7.44 county of cook 

Date Prem.ieea Sold 6/3/2016

certificate No. -=-1~4~-~0~0~0~2~7~1~5----------

Sold for General. -Taxes of =2~0~1~4'-,--:-:--:--:---:-:---:------:-: sold for Special Assessment of (Municipal.tty), N/A 

And Special Aseeeement Numloer: N/A 

Warrant No. N/A msT. NUMBER, N/A 

TRIS PROPERTY HAS BERN SOLD FOR DBL.INQtraNT TAXBS 

SEP 2-72016,tProperty l ocated at 7225 N KOSTNBR AVB unit A, LINCOLNWOOD, IL 60712 

Legal Description or Property Index N0.10- 27 - 4 24-046-1001 VOL.125 

This notice is t o advise you that the above property has been sold 

for delinquent taxes and that the period -o f redemption from the sal e will 

expire on 3/29/2017. 

This notice is also to advise you that a petition wil l be f iled for a 

tax deed which will transfer title and the right to possession of this 

proporty if redemption is not made ·on or be.Co.re 3/29/20i7. 

At the date of this notice the total amoun t which you must pay in 

order t o redeem the above property is $47, 340 .01.. 

YOU ARB URGED TO REDBEM INMBDI.l\'l'ELY TO PREVENT LOSS OP PROPE'liTY. 

Redemption can be made at any time on or before 3/29/2017 by applying 

to the County Cl.erk of Cook county, Illinois, at the Office of t h e County 

Clerk in Chicago, Illinois. 

The above amount is subject to increase at 6 month intervals from t he 

date of sale. Check with the county clerk as t o the exact amount you owe 

before redeeming. Payment must be made by certified check, cashio.r's 

check, money order or in cash . 

For furthe r information contact the county Clerk. 

ADDRESS, 118 N. Cl.ark St., Room 434 Gan C LLC 

TELBPHONE: Chicago, I L 60602 

31.2 -603-5645 

Purchaser or Assignee 

Dat@d: 9/27/16. 

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T,~X OBED No. 2017 COTO 002611 F'UEO: ---"A"-PR"'I'-'L'--"l "-1,... , -'2'-'0'-'l'-'7-

TARE NOTICE 

COUNTY Of Coo~ 

DAT£ PREMISES SOLO __ J~u_n_e~ 3~·-2~0_1~6 _______________ _ 

Cr.R't!FICATE NUM8ER ---=l_,4_-.=0.=0.=0,.:2c..c7_.,1"'5'---------------­ SOLD FOR GENERAL TAXES or (YEAR) 2014 ( 2 013 INCL0) 

SOLO FOR $P£ClAL AS$E$SM£N'r OF' (MtJNICIPAt.l'l'Y) __ N~/_A ________ _ 

ANO SPECIAL ASSESSMENT NU!''8ER N/A WARRANT NUMBER: N/A ----I N_S_T ___ N_U_MB_E_R ___ N~/_A ____ _ 

THIS PROPERTY HAS BEEN SOLO FOR DELIN9UENT TAXES. 

PROPERTY LOCA1'50 AT UNIT A, 7225 N. KOSTNER AVE:. , LINCOLNWOOD, IL 

LEGAL DESCRIPTION OR PERMANENT INDEX NUr<BER 10- 27-424-046-1001 

'!'his notice i s to advise you that t he above property has been sold 

for delinquent taxes and that the period of redemption f rom sale 

will expire on Sep tember 13, 2017 . 

The amount to redeem is subject to increase at 6-month intervals 

from the date o f sale and may be further increased if t he purchaser 

at t he tax sal e or his or her assignee pays any subsequently 

accruing taxes or speci al assessments to redeem the p roperty from 

subsequent forfei t ures or tax sales. Check with the County Clerk as 

to the exact amoun t you owe before redeeming, 

This notice i s also to advise you that a Petition has been filed for a tax deed, which will transfer tit l e and the right of possession of 

this property i f redemption is not made on or before September 13, 

~ -

This matter is set for hearing in the Circuit Court of Cook County, 

Richard J. Da ley Center, 50 West Washington Street, Room 1704, 

Chicago, Illinoi s, at 9:30 A.M. on October 6, 2017 . 

You may b e present at this hearing, but your right to r edeem will 

already have expired at that time. 

You ARE URGED TO REDEEM IMMEDIATELY To PREVENT Loss OF PROPERTY. 

Redempti on can be made at any time on or before September 13, 2017 

by applying to the County Clerk of cook County, Illinois, at the 

Offi ce of t he County Clerk, 118 N. Cl ark St . , Room 434 , Chicago, IL . 

FOR FURTHER INFORMATION CONTACT T HE COUNTY CLERK 

ADDRESS : 118 N. CJ..ARK ST. , ROOH 4 34 

CHlCJ\GO, IL 60602 

TELEPHONE : (312) 603-5645 

MAIL TO THE FOLLOWING PE:RSONS : 

(SE:E REVERSE SI DE) 

C LERK or THE 1-@(CUI T COURT 

DATED: APRIL 11 , 2017 

I 

I 

! 

¶ 56 Appendix II 

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CASE NO. 2017 COTO 002Jill 

I. 6420 N. Longmeadow, LLC, c/o Richard Tinimbang, 7225 N. Kostner Ave., 

Unit B, Lincolnwood, IL 60712; 

2. 6420 N. Longmeadow, LLC, cio Don Michael Tinimbang, 7225 N. Kostncr Ave., 

Unit B, Lincolnwood, IL 60712; 

3. 6420 N. Longmeadow, LLC, c/o Donna Joann Tinimbang, 7225 N. Kostner Ave., 

Unit B, Lincolnwood, IL 60712; 

4. Richard Tinimbang, 6451 N. Leroy Ave., Lincolnwood, lL 60712; 

5. Don Michael Tinimbang, 1600 S. Indiana Ave., #1705, Chicago, IL 60616; 

6. Don Michael Tinimbang, 6420 N. Longmeadow Ave., Lincolnwood, IL 60712; 

7. Donna Joann Tinimbang, 4851 W. Greenleaf Ave., Unit H, Lincolnwood, IL 60712; 

8. JCH Home Health Care, 7225 N. Kostner Ave., Unit A, Lincolnwood, IL 60712; 

9. Occupant, 'J2'l':> N. Kostncr Ave., Unit A, Lincolnwood, IL 60712; and 

10. !SN Corporation, 10411 Motor City Dr., Bethesda, MD 20817. 

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