Appeal guide · Illinois
How to appeal a commercial assessment in Cook County
8 steps from the notice to the Cook County Board of Review and beyond, with the forms, exchange deadlines and mistakes that decide commercial cases here.
Deadline
Assessor: 30 calendar days beginning on the date Notices of Proposed Assessed Valuation are issued for the township (the last file date is printed on the notice). Board of Review: the township's filing window, set by the Board each year and open at least 30 days
Where to file
Assessor: SmartFile online appeals with the RPIE Online Form; Board of Review: Digital Appeals Processing System (DAPS) portal
Statute
35 ILCS 200/16-95 (Board of Review, counties of 3,000,000 or more); 35 ILCS 200/16-160 (Property Tax Appeal Board)
The process, in order
Assessor appeals are decided on the written record by the office's commercial valuation staff. At the Board of Review, analysts review commercial complaints on the documents; attorneys may argue at hearing calls scheduled by the Board, limited to eight dockets per call, and failure to appear waives oral argument. A re-review request must be filed within 3 days of the Board's letter and cannot raise a new legal theory.
Forms you will need
- +Assessor commercial appeal (SmartFile) with RPIE statement
- +Board of Review complaint
- +Board of Review Attorney Authorization Form
- +Vacancy-Occupancy Affidavit
- 1
Before the township's notice date
Check the township calendar
Pull the Assessor's assessment and appeal calendar, note the township's reassessment notice date and last file date, and confirm the PIN's class code and the prior three years of assessed values.
- 2
As soon as the notice arrives
Assemble RPIE and operating history
Gather three years of Schedule E or Form 8825 data, the current rent roll, leases and any purchase documents, then complete the RPIE filing with the PIN's 10-character RPIE code. Without timely RPIE data the commercial appeal is not evaluated.
- 3
By the township's last file date (about 30 days from the notice)
File the Assessor appeal in SmartFile
Practitioners must file through SmartFile. Upload the income analysis, sales comparables or appraisal, and a notarized vacancy affidavit if vacancy is claimed. Evidence filed after the township closes is not accepted.
- 4
When the township's appeal results are released
Review the Assessor's result
Compare the revised assessed value with the indicated value at the 25% level and decide whether the remaining gap justifies a Board of Review complaint.
- 5
During the township's Board of Review window (open at least 30 days)
File the Board of Review complaint
File through the Board's online portal, with the Attorney Authorization Form submitted before the complaint is finalized. Entity owners must be represented by an Illinois attorney.
- 6
Evidence deadline set for the township group
Upload evidence by the Board's deadline
Submit the Rule 20 income package (three years of Schedule E, or an affidavit with an income and expense statement), the Historical Summary Form, rent rolls and any USPAP appraisal. Late evidence is generally refused.
- 7
Hearing calls set by the Board; re-review within 3 days of the decision letter
Hearing and re-review
Argue at the scheduled call or rest on the written record. A re-review request must state one of the Board's listed grounds and cannot introduce a new factual argument.
- 8
Within 30 days of the Board's written decision
Appeal to PTAB or circuit court
File with the Illinois Property Tax Appeal Board, which treats the deadline as jurisdictional, or pay the taxes and pursue a tax objection complaint in the Circuit Court of Cook County.
Mistakes that lose Cook County appeals
- Filing the Assessor appeal without RPIE data, which leaves the appeal incomplete and unevaluated.
- Submitting actual income without showing that rent, vacancy and expenses reflect the market; the Board and PTAB discount operating history that is not tied to market evidence.
- Finalizing the Board of Review complaint before the Attorney Authorization Form is in; late authorizations are rejected.
- Relying on an appraisal dated outside the triennial period, or one that skips the income approach on an income-producing building.
- Claiming vacancy relief without the Vacancy-Occupancy Affidavit, dated interior photos and proof of leasing efforts.
Evidence rules
- 1.Assessor: the appeal and all supporting evidence must be filed by the township's closing date, and RPIE data for income-producing property is due by the same date. Nothing is accepted after the township closes except in a system error.
- 2.Board of Review Rule 20: leased or leasable property must include Schedule E of Form 1040 for the three years before the lien date, or an affidavit plus a property-level income and expense statement; for multi-tenant buildings the Board will consider lease summaries, audited financial statements and rent rolls with totals.
- 3.Board of Review Rule 19: appraisals must follow USPAP, be prepared by an Illinois licensed or certified appraiser, value the property as of the January 1 lien date, include an income approach for income-producing property (or explain its omission), and disclose any appraisal made within three years before the lien date.
- 4.Board of Review Rule 14(B): a complete Historical Summary Form is required for income-producing property other than Class 2 residential.
- 5.Board of Review Rule 21: vacancy relief requires the Vacancy-Occupancy Affidavit, dated interior photographs of the vacant space, and documentation of leasing efforts.
Frequently asked
Do I have to appeal to the Assessor before going to the Board of Review?
No. The Board of Review accepts complaints whether or not an Assessor appeal was filed, and it hears appeals every year. Filing at both levels gives two chances at a reduction in the reassessment year.
Is commercial property in Cook County really assessed at 25%?
Yes. Class 5a commercial and Class 5b industrial property is assessed at 25% of market value under the Cook County classification ordinance, and Class 3 apartments are at 10%. A $40 million office building therefore carries a $10 million assessed value before the state equalization factor is applied.
How long do I have to appeal to PTAB?
30 days from the Board of Review's written notice of decision, or 30 days from the Board's transmittal of the township to the Assessor, whichever is later. PTAB treats the deadline as jurisdictional, so a late petition is dismissed.
Can a property manager sign the Board of Review complaint for an LLC owner?
No. Other than individuals appearing for themselves, parties before the Board of Review must be represented by an attorney, including corporations and LLCs. The Assessor's level has no such requirement, although practitioners there must file through SmartFile.
File a stronger Cook County appeal this cycle.
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