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FOURTH DIVISION 
JUNE 28, 2001

PRESIDING JUSTICE HARTMAN delivered the opinion of the court:

Petitioner, Phoenix Bond & Indemnity Company (Phoenix),appeals the circuit court's denial of its motion to expungeredemption against respondents John and Joann Bacino (the Bacinos)and David D. Orr, County Clerk of Cook County. In its motion,Phoenix asserted that the Bacinos' redemption deposit, submitted onJanuary 31, 2000, 24 months and 1 day from the date of the taxsale, was insufficient and inadequate, and did not comply withsection 21-355 (b)(5) (35 ILCS 200/21-355 (b)(5) (West 1998)) ofthe Illinois Property Tax Code (35 ILCS 200/1-1 et seq. (West 1998)(Code)). Respondents contended that because January 30, 2000, thedate of expiration of an accrued penalty period, fell on a Sunday,section 1.11 (5 ILCS 70/1.11 (West 1998) (section 1.11)) of theStatute on Statutes (5 ILCS 70/0.01 et seq. (West 1998)) extendedthe deadline to submit payment at four times the penalty bid rateuntil the next business day, Monday, January 31, 2000. The circuitcourt denied Phoenix's motion, refusing to bifurcate the issues ofredemption expiration and penalty accrual. Phoenix appeals.

The legal issue presented is whether section 1.11 isapplicable to abate the expiration of an accrual period for penaltyrates for the purposes of assessing the amount of tax redemptionowed.

On January 30, 1998, the Cook County Collector conducted itsannual sale of delinquent real estate taxes for the 1996 tax year. At that sale, Phoenix purchased a lien for delinquent real estatetaxes on property identified as permanent index number 30-08-402-002-0000 (subject premises). As evidence of its completedacquisition, Phoenix received a certificate of purchase. At thetime of sale, the Bacinos had an interest in the subject premises.

On January 14, 2000, the county clerk of Cook County preparedan official estimate of cost of redemption for the subjectpremises. The estimate is returned to the clerk once redemptionoccurs. The estimate in the instant matter, when issued to theBacinos on January 18, 2000, indicated that because more than 18and less than 24 months had passed since the 1998 tax sale, theaccrued penalty due amounted to $7,503.28, which was calculated bymultiplying the penalty period times four and dividing thatpercentage into the certificate amount paid by Phoenix at the sale. Further, the estimate stated that "[s]ale penalties increase every6 months from the date of sale," and an additional penalty of 18%amounting to $1,875.82 would be added after January 30, 2000, whichfell on a Sunday. The total cost of redemption until January 30,2000, including fees, penalties, and subsequent taxes, equaled$40,452.35.

On Monday, January 31, 2000, the Bacinos delivered theestimate to the clerk together with their redemption, totaling$40,452.35, which did not include the $1,875.82 that the estimate stated on its face was to have been a part of any redemption madeafter January 30, 2000. The office of the county clerk of CookCounty was closed on Sunday, January 30, 2000. Nevertheless, theclerk accepted the redemption payment at four times the penaltyrate on the next business day.

On February 9, 2000, Phoenix filed a motion to expungeredemption, challenging the amount paid by the Bacinos and acceptedby the clerk to redeem the subject premises. Phoenix contendedthat the redemption deposit was insufficient and inadequate becauseit was made after 24 months from the date of sale and,consequently, should have included $1,875.82, the accrued amounttotaling five times the penalty rate, instead of four times thepenalty rate.

In their responses to Phoenix's motion, both the clerk and theBacinos cited section 1.11,⁽¹⁾

arguing the Bacinos could not redeemon a Sunday and were, therefore, entitled to redeem on thesucceeding Monday without any change in the amount of the depositdespite the passage of 24 months from the date of sale on theprevious day. Phoenix replied to those answers by distinguishingbetween the act of redemption, which legally could not expire on aSunday, and the accrual of penalty rates, which occurs on the firstday of each succeeding six-month period from the date of sale.

On May 22, 2000, the circuit court denied Phoenix's motion toexpunge, stating that the court would not "bifurcate the issue ofredemption and penalty." From this ruling, Phoenix appeals.

Phoenix asserts that the accrual of a penalty on a taxcertificate, which evidences the sale of the county collector'sjudgment, is similar to accruals of interest on any other judgmentor debt and, therefore, is neither subject to abatement on non-business days, nor defined as an act that the judgment debtor mustperform. Phoenix argues that the Bacinos' right to redeem did notexpire on Monday, January 31, 2000; instead, the amount necessaryfor redemption increased as of that date. As a result, Phoenixmaintains that the semi-annual accrual of penalty should begoverned by the Code and not by the time constraints of section1.11.

Respondents argue that the taxpayer's act of depositingpayment to redeem his property cannot be separated from thedetermination of the penalty amount owed. Respondents contend thatwhere the last day to redeem at a specified rate occurred on aSunday, it follows that the taxpayer could redeem the subjectpremises the next business day pursuant to section 1.11. The actof redemption cannot take place on a Sunday and, therefore,according to respondents, the clerk properly excluded January 30,2000, from the computation of the penalty accrual period.

The Code provides that after judgment has been renderedagainst property for nonpayment of taxes and the requisite noticehas been issued, the county collector may offer the property forsale at a public tax sale. See 35 ILCS 200/21-190 (West 1998). Upon sale of the property, the county clerk issues a certificate ofpurchase to the buyer, countersigned by the collector, whichdescribes the property. See 35 ILCS 200/21-250 (West 1998). Thecertificate indicates the date of sale, amount of taxes, specialassessments, interest, and costs for which the property was sold,and confirms that payment of the sale price has been made. See 35ILCS 200/21-250 (West 1998). Issuance to a tax buyer of acertificate of purchase for delinquent taxes does not affect thedelinquent property owner's legal or equitable title to theproperty. See In re Petition of Conrad Gacki Profit Sharing Fundfor Tax Deeds, 261 Ill. App. 3d 982, 984, 634 N.E.2d 1281 (1994). The owner or person interested in the property has the right toredeem the property from the tax sale. See 35 ILCS 200/21-345(West 1998).

Sections 21-345 (35 ILCS 200/21-345 (West 1998)) and 21-350(35 ILCS 200/21-350 (West 1998)) of the Code prescribe the mannerand method of redemption and the time period for redemption,respectively. Section 21-355 (35 ILCS 200/21-355 (West 1998)(section 21-355)) of the Code sets out provisions for establishingthe amount of the tax redemption, calculated by the cost of thecertificate of purchase plus a penalty, computed through the dateof redemption as a percentage of the certificate amount.⁽²⁾

The instant case requires interpretation and application ofthe Code and other provisions of Illinois law. Questions ofstatutory construction are reviewed de novo. In re Application forTax Deed, 285 Ill. App. 3d 930, 932, 675 N.E.2d 285 (1997). Theprimary rule of statutory construction is to ascertain and giveeffect to the intent of the legislature. People ex rel. Baker v.Cowlin, 154 Ill. 2d 193, 197, 607 N.E.2d 1251 (1992) (Cowlin). Indetermining legislative intent, the first step involves examiningthe language of the statute. People v. Dinger, 136 Ill. 2d 248,257, 554 N.E.2d 1376 (1990). Legislative intent as to the meaningof words can be ascertained from the history of the legislation orfrom the use of terms in other sections of the same or otherstatutes. Christ Hospital & Medical Center v. IllinoisComprehensive Health Insurance Plan, 295 Ill. App. 3d 956, 961, 693N.E.2d 1237 (1998). Where the statutory language is clear, it willbe given effect without resort to other aids for construction. Cowlin, 154 Ill. 2d at 197. If the statutory language isambiguous, the court can consider the purpose behind the law andthe evils the law was designed to remedy. Wagner v. City ofChicago, 166 Ill. 2d 144, 149, 651 N.E.2d 1120 (1995). The court,however, must construe the statute as written and may not, underthe guise of construction, supply omissions, remedy defects, annexnew provisions, add exceptions, limitations, or conditions, orotherwise change the law so as to depart from the plain meaning ofthe language employed in the statute. Toys "R" Us, Inc. v.Adelman, 215 Ill. App. 3d 561, 568, 574 N.E.2d 1328 (1991).

Illinois law favors redemptions, and the redemption statuteswill be liberally construed unless injury to the tax purchaserresults. In re Application of the Cook County Treasurer, 185 Ill.2d 428, 432, 706 N.E.2d 465 (1998). The Code provides that inorder to effect timely a redemption at a penalty rate four timesthe bid amount, the redemption must occur within an 18 to 24 monthperiod after the date of the tax sale. 35 ILCS 200/21-355 (b)(4) (West 1998) (section 21-355(b)(4)). Illinois courts previouslyhave applied section 1.11 to the expiration of the redemptionperiod. See M.E. Stein & Co. v. Jones, 13 Ill. App. 3d 184, 300N.E.2d 553 (1973); John Allan Co. v. Sesser Concrete Products Co.,114 Ill. App. 2d 186, 252 N.E.2d 361 (1969) (John Allan Co.);Pettigrove v. Parro Construction Corp., 44 Ill. App. 2d 421, 194N.E.2d 521 (1963) (Pettigrove).

In John Allan Co., the applicable period for a taxpayer toredeem his property expired on Saturday, August 12, 1967. Instead,the taxpayer redeemed his property on Monday, August 14, 1967.Although evidence was presented that indicated the clerk's officewas open on Saturday, August 12, the court determined that pursuantto section 1.11 (Ill. Rev. Stat. 1969, ch. 131, par. 1.11), theexpiration date for redemption was extended to the followingMonday. John Allan Co., 114 Ill. App. 2d at 191. Similarly, inPettigrove, the court held that as a practical matter, where anoffice is closed on the final day for the doing of any act providedby the law to be completed, that day should be excluded, and theact may take place the first day on which the clerk's office isopen. 44 Ill. App. 2d at 426-27.

Illinois courts have also applied section 1.11 to determinethe proper method for judgment debtors to stop the accrual ofinterest on a judgment. See Halloran v. Dickerson, 287 Ill. App.3d 857, 869, 679 N.E.2d 774 (1997) (Halloran). In Halloran, aftera judgment of $2.5 million was entered in favor of plaintiff, theestate of a motorist who had been killed in an automobile accident,the insurer for defendant, whose policy limit was $25,000,submitted payment of that limit and its calculation of interest upto that time to the clerk of court. When plaintiff requested thatthe clerk release the funds from the account, the insurer objected. Eventually, the parties agreed to suspend the accrual of interest. Thereafter, the circuit court held that the insurer was liable foradditional interest. On appeal, the appellate court determined amethod to calculate the interest owed on the judgment, utilizingsection 1.11 to resolve the starting and ending dates of accrual. Halloran, 287 Ill. App. 3d at 863, 869.

Although Illinois courts have applied section 1.11 in thecases discussed above, there is no precedent applying section 1.11to the expiration of an accrual period for a penalty rate to redeema tax purchase. Both petitioner and respondents submitted numerousexamples of cases applying section 1.11,⁽³⁾ but neither provided anexplanation as to why the issues of redemption expiration andpenalty accrual should be conjoined or bifurcated, and the Codecontains no express provisions for dealing with this situation.

To resolve the issue of whether section 1.11 applies to theaccrual of a penalty period in the instant case, it is necessary todetermine whether the accrual of penalty rates constitutes an "actprovided by law" to be completed unless the last day is a Saturday,Sunday, or holiday.

Phoenix argues that unlike the "act" of redemption, theaccrual of a penalty rate is not an "act" that can be performed bythe delinquent tax redeemer according to the wording of section1.11. Phoenix misinterprets the clear and unambiguous statutorylanguage of both sections 1.11 and 21-355. The plain meaning ofsection 1.11 allows for an extension of "time within which any actprovided by law" is to be done, if the expiration of performanceoccurs on a Saturday, Sunday, or holiday. (Emphasis added.) 5ILCS 70/1.11 (West 1998). Similarly, section 21-355 unambiguouslyprovides that a delinquent tax redeemer accrues a penalty whichincreases after the expiration of every six-month period until thetermination of the 30-month redemption period.

In the case sub judice, the determination of the redemptiondate and the calculation of the penalty are interrelated to theextent that the penalty is fixed by the redemption date. Section21-355 supports this construction in that it refers to "the accruedpenalty, computed through the date of redemption"; and section 21-355(b)(4) provides for computation of the accrued penalty when the"redemption occurs *** before the expiration of 24 months from thedate of sale." Here, since the redemption date (the "act providedby law") is to be computed by excluding January 30, 2000, becausethat date fell on a Sunday (section 1.11), then the computation ofthe 24-month period from the date of sale to the date of redemptionas provided in section 21-355(b)(4) also must be accomplished byexcluding January 30, 2000. Respondents, having redeemed onJanuary 31, 2000, did so before the expiration of 24 months fromthe date of sale because January 30, 2000 was excluded indetermining the date of redemption.⁽⁴⁾

Accordingly, the decision of the circuit court of Cook Countyto deny Phoenix's motion to expunge redemption is affirmed and theBacinos properly redeemed the subject premises by paying theaccrued penalty at four times the rate pursuant to section 21-355(b)(4).⁽⁵⁾

Affirmed.

HOFFMAN and BARTH, JJ., concur.

1. Section 1.11 of the Statute on Statutes provides:

"The time within which any act provided by lawis to be done shall be computed by excludingthe first day and including the last, unlessthe last day is Saturday or Sunday or is aholiday as defined or fixed in any statute nowor hereafter in force in this State, and thenit shall also be excluded. If the daysucceeding such Saturday, Sunday or holiday isalso a holiday or a Saturday or Sunday thensuch succeeding day shall also be excluded." 5 ILCS 70/1.11 (West 1998).

2. Section 21-355 provides in pertinent part:

"Any person desiring to redeem shall depositan amount specified in this Section with thecounty clerk of the county in which theproperty is situated *** payable to the countyclerk of the proper county. The deposit shallbe deemed timely only if actually received inperson at the county clerk's office prior tothe close of business as defined in Section 3-2007 of the Counties Code on or before theexpiration of the period of redemption or byUnited States mail with a post officecancellation mark dated not less than one dayprior to the expiration of the period ofredemption. The deposit shall be in an amountequal to the total of the following:

(a) the certificate amount, which shallinclude all tax principal, specialassessments, interest and penalties paid bythe tax purchaser together with costs and feesof sale and fees paid under Sections 21-295and 21-315 through 21-335;

(b) the accrued penalty, computed through thedate of redemption as a percentage of thecertificate amount, as follows:

***

(4) if the redemption occurs after 18 months from the date of sale and on or before the expiration of 24 months from

the date of sale, the certificate amount times 4 times the penalty bid at sale; (5) if the redemption occurs after 24

months from the date of sale and on or before the expiration of 30 months from the date of sale, the certificate amount

times 5 times the penalty bid at sale; **

*." 35 ILCS 200/21-355 (West 1998).

3. See e.g., Board of Education of the City of Chicago v.Wolinsky, 842 F. Supp. 1080 (N.D. Ill. 1993) (where the statute oflimitations period for filing a civil action expires on a weekendor holiday when courts are closed, the period is extended to thenext business day); People v. Montenegro, 203 Ill. App. 3d 314, 560N.E.2d 934 (1990) (in computing the last day of the 120-day periodwithin which a "speedy" trial must occur, holidays, Saturdays, andSundays are not included); Strozewski v. Sherman Equipment Co., 76Ill. App. 3d 266, 395 N.E.2d 38 (1979) (motions to vacate ordersare considered filed within statutory 30-day period where the 30th day following a dismissal order fell on a Sunday and the motion wasfiled the next day).

4. This is not to say that, prior to the date of finalredemption, section 1.11 should be construed as interfering withaccrual of ongoing interest.

5. Also , it should be noted that the State raised an additionalargument that while the penalty rates increase every six monthsfrom the date of sale, the determination of the date on which thepenalty increases is subject to approval by the clerk at the timethe property owner tenders his redemption. The State did notprovide case law in support of its contention in contravention ofSupreme Court Rule 341(e)(7). 177 Ill. 2d R. 341(e)(7). Barecontentions without argument or citation of authority do not meritconsideration on appeal. See Fuller v. Justice, 117 Ill. App. 3d933, 942-43, 453 N.E.2d 1133 (1983). Therefore, this argument iswaived. See Nancy's Home of the Stuffed Pizza, Inc. v.Cirrincione, 144 Ill. App. 3d 934, 939, 494 N.E.2d 795 (1986).