IN THE ILLINOIS INDEPENDENT TAX TRIBUNAL Wachovia Securities Financial Holdings, LLC ) ) Petitioner, ) ) v. ) No. ) The Illinois Department of Revenue , ) ) Defendant. ) PETITION Petitioner, Wachovia Securities Financial Holdings, LLC ("Petitioner"), by and through its attorneys, Horwood Marcus & Berk, Chartered, complains of the Defendant, the Illinois Department of Revenue ("Department"), and alleges as follows: PARTIES 1. Petitioner's principal place of business is at One North Jefferson, St. Louis, Missouri, 63103, and Petitioner's mailing address for tax purposes is 401 South Tryon Street, Dl050-240, Charlotte, North Carolina 28202. 2. Petitioner is represented by Horwood Marcus & Berk Chartered attorneys Marilyn A. Wethekam and Breen M. Schiller locatc::d at 500 West Madison St., Suite 3700, Chicago, Illinois 60661, and can be reached at 312-606-3240 or
[email protected] or
[email protected] and 312-606-3220. 3. Petitioner's FEIN is 72-1560834. 4. Petitioner's Illinois Account Number is 16819-02592. 5. The Department is an agency of the Executive Department of the State Government and is tasked with the enforcement and administration of Illinois tax laws. 20 ILCS 5/5-15. 1 3037888/1/11028.003 NOTICE 6. On February 2, 2016 the Department issued Petitioner a Notice of Claim Denial ("Notice") for the taxable year ending December 31, 2012 ("Year at Issue") denying Petitioner's claim for refund of its Illinois partnership replacement tax overpayments in the amount of $429,339. 7. A true and accurate copy of the Notice is attached hereto as Exhibit A. JURISDICTION 8. Petitioner brings this action pursuant to the Illinois Independent Tax Tribunal Act ("Tribunal Act"), 35 ILCS 1010/1-1 to 35 ILCS 1010/1-100.