86 Ill. Adm. Code 850.200
Detrimental Reliance
Section
850.200 Detrimental Reliance
In any
subsequent audit of the taxpayer by the Department, detrimental reliance that
is based upon the results of the certified audit that the qualified
practitioner conducts, or incorrect or misleading advice that the qualified
practitioner gives, is not a defense against the assessment of tax, penalty, or
interest.