Peo. Ex Rel. Nordland v. Home for the Aged

The plaintiff, Leland J. Nordlund, ex officio County Collector of Winnebago County, applied for a judgment of sale for delinquent
taxes assessed for the year 1965 against property of the defendant, The Association of The Winnebago Home for the Aged. The
defendant filed timely objections on the ground that the collector had been enjoined from placing its property on the tax
rolls by a prior order of the county court of Winnebago County, entered March 7, 1960; that said order had never been vacated
and, therefore, these proceedings are a collateral attack on that decree and invalid. It further asserted that the real estate
was tax exempt during the period in question because actually and exclusively used for charitable and beneficent purposes
as an old people's home pursuant to the provisions of section 19.7 of the Revenue Act of 1939. (Ill. Rev. Stat. 1965, chap.
120, par. 500.7.) The trial court entered a decree denying defendant's objections and upholding the judgment for the taxes
as assessed. The revenue being involved defendant appealed directly to this court. Defendant's appeal poses two questions: (1) Are these proceedings invalid as a collateral attack on a prior decree of the
Winnebago County Court entered March 7, 1960, and (2) Is defendant's property exempt from taxation under our constitution
and applicable statute?