The law is well settled that taxing bodies retain broad discretion in estimating the dollar amounts necessary to carry out their lawful objectives. In re Application of Rosewell, 159 Ill.2d 393, 401, 639 N.E.2d 559, 562 (1994); In re Application of the People ex rel. Anderson, 279 Ill. App.3d 593, 596, 665 N.E.2d 521, 523 (1996). Thus, taxing bodies may proceed to levy real estate taxes based upon these estimates.

¶ 22 A taxing body has wide discretion in estimating the amount of money necessary to carry out its lawful objectives, and there is a presumption a taxing body did not abuse its discretion in making its property tax levy. In re Application of the People ex rel. Anderson, 279 Ill.App.3d 593, 596 (1996); In re Application of Rosewell, 159 Ill.2d 393, 402 (1994) (abuse of discretion is the proper standard of review of a taxing body's estimates in passing their appropriation and levy ordinances as part of their budgets). To rebut that presumption, an objector must make a prima facie case that a levy for a fund created an unlawful accumulation of assets.

Id. at 545. The Districts also cited this court's application of the Miller analysis in In re Application of the People ex rel. Anderson, 279 Ill. App. 3d 593, 598 (1996), in which we found that calculations of 1.8 times the average annual expenditure for the past three years and 1.61 times the previous year's expenditure fell "well below" what Miller found to be excessive and that the objectors had failed to sustain their burden of proving an excess accumulation. The District then attached as exhibits affidavits and worksheets regarding calculations of the "Funds/Average Expenditure Ratio" for each district and relevant fiscal year. None of the calculations revealed a ratio that exceeded 1.49516.

Id. at 543, 248 N.E.2d 89. The court concluded that the tax levy resulted in an excess accumulation. Id. at 545, 248 N.E.2d 89. The Districts also cited this court's application of the Miller analysis in In re Application of the People ex rel. Anderson, 279 Ill.App.3d 593, 598, 216 Ill.Dec. 461, 665 N.E.2d 521 (1996), in which we found that calculations of 1.8 times the average annual expenditure for the past three years and 1.61 times the previous year's expenditure fell “ well below” what Miller found to be excessive and that the objectors had failed to sustain their burden of proving an excess accumulation. The District then attached as exhibits affidavits and worksheets regarding calculations of the “Funds/Average Expenditure Ratio” for each district and relevant fiscal year. None of the calculations revealed a ratio that exceeded 1.49516.

Id. at 545. The Districts also cited this court's application of the Miller analysis in In re Application of the People ex rel. Anderson, 279 Ill. App. 3d 593, 598 (1996), in which we found that calculations of 1.8 times the average annual expenditure for the past three years and 1.61 times the previous year's expenditure fell "well below" what Miller found to be excessive and that the objectors had failed to sustain their burden of proving an excess accumulation. The District then attached as exhibits affidavits and worksheets regarding calculations of the "Funds/Average Expenditure Ratio" for each district and relevant fiscal year. None of the calculations revealed a ratio that exceeded 1.49516.

Moreover, as the village points out, the district's operating budget for 2008-09 was about $74 million; the jury award in this case was $14.2 million; and much greater surpluses have been upheld. See In re Application of the People ex rel. Anderson, 279 Ill. App. 3d 593, 597 (1996); see also In re Application of County Collector, 41 Ill. App. 3d 106, 111 (1976) ("[T]he courts have frequently upheld levies despite large cash balances on hand where no improper purpose was shown"). Similarly, the district's second complaint involves the application of the Property Tax Extension Limitation Law ( 35 ILCS 200/18-185 et seq. (West 2008)).