## Facts

- The Chicago Park District adopted an appropriation ordinance that set aside funds for “custodial care” of certain school facilities.
- The ordinance stated that the school facilities were used in connection with the Park District’s recreational activities and programming.
- W. E. Brewster, a taxpayer, challenged the validity of the Park District’s appropriation and the tax extended on the basis of that appropriation.
- The dispute arose in the context of Cook County tax collection proceedings involving taxes extended for the Park District.
- The trial court rejected Brewster’s challenge and determined that the appropriation was valid.
- Brewster appealed from the judgment overruling his objection.

## Issues

1. Whether the Chicago Park District’s appropriation of funds for custodial care of school facilities used for the Park District’s recreational activities was a lawful Park District purpose supporting a valid tax.

## Decision

- The appellate court affirmed the trial court.
- The court held that the Park District’s appropriation for custodial care of school facilities used for Park District recreation was valid.
- Because the appropriation was authorized, the related tax extension was upheld and the taxpayer’s objection was properly overruled.

## Legal Principles

- A local taxing body’s appropriation is valid if it serves a purpose the entity is authorized by statute to carry out, including reasonable expenses that are incidental to that purpose.
- A park district may spend public funds on costs reasonably connected to providing recreational programs and facilities, even when the facilities used are not owned by the park district.
- In a tax objection proceeding, the objector bears the burden to show that the challenged appropriation is clearly outside the taxing body’s authority; absent such a showing, courts will sustain the tax.

## Conclusion

The court upheld the Chicago Park District’s tax because the challenged appropriation—funding custodial care for school facilities used in Park District recreational activities—was a permissible expenditure tied to the Park District’s authorized recreational functions, and the taxpayer did not establish that the item was beyond the District’s lawful authority.


People ex rel. Korzen v. Brewster, 304 N.E.2d 46 (1973)