To the extent that the Tax Code does not regulate matters of procedure, the Civil Code applies. See People ex rel. Southfield Apartment Co. v. Jarecki,In re Application of the Cook County Collector for Judgment & Order of Sale Against Lands & Lots Returned Delinquent for Nonpayment of General Taxes for the Year 1987 & Prior Years, 408 Ill. 266, 274, (1951) ('where the Revenue Act [the statute that formerly contained the relevant provisions of the Tax Code] is silent, * * * the Civil Practice Act and rules of court apply'); 271 Ill.App.3d 12, 16, [207 Ill.Dec. 697, 648 N.E.2d 153] (1995) ('To the extent that the Revenue Act does not regulate matters of procedure, the Code of Civil Procedure applies'); In re Application of Rosewell, 236 Ill.App.3d 165, 168-69 [177 Ill.Dec. 611, 603 N.E.2d 681] (1992) [(same)]. * * * While the Tax Code contains a section relating to procedures for and adjudication of tax objections [citation], objectors do not cite, and we have been unable to locate, any provision in the Tax Code in which intervention is regulated. Accordingly, we find that the Civil Code's intervention ABN Ambro Services Co. v. Naperville Park District, provision applies to proceedings under the Tax Code.

To the extent that the Property Tax Code does not regulate matters of procedure, the Code of Civil Procedure applies. In re Application of the Cook County Collector for Judgment Order of Sale Against Lands Lots Returned Delinquent for Nonpayment of General Taxes for the Year 1987 Prior Years, 271 Ill. App. 3d 12, 648 N.E.2d 153 (1995) ( CNA Tax Investors). The Code of Civil Procedure states that in proceedings in which the procedure is regulated by other statutes, those other statutes control; but article II of the Code applies to matters of procedure not regulated by other such statutes.

The trial court's determination as to diligence "will not be reversed on appeal unless it is against the manifest weight of the evidence." Gacki v. La Salle National Bank, 282 Ill. App. 3d 961, 964, 669 N.E.2d 936, 938 (1996); see also In re Application of the Cook County Collector for Judgment & Order of Sale Against Lands & Lots Returned Delinquent for Nonpayment of General Taxes for the Year 1987 & Prior Years, 271 Ill. App. 3d 12, 15, 648 N.E.2d 153, 156 (1995) ("Because diligence is a question of fact, the trial court's determination will only be reversed if it is against the manifest weight of the evidence.").¶ 31 In this case, the record reflects petitioner relied on records from the assessor's office and the treasurer's office when determining which parties were entitled to notice under the Code. He neither discovered nor investigated the parties who held interests in the property as shown by the records of the Macon County recorder's office.

Where the statute fully regulates a given matter of procedure, it will preempt the Civil Practice Law with respect to that matter. See In re Application of the Cook County Collector for Judgment Order of Sale Against Lands Lots Returned Delinquent for Nonpayment of General Taxes for the Year 1987 Prior Years, 271 Ill. App.3d 12, 16, 648 N.E.2d 153, 156 (1995). In the present case, we agree with the Department that the UTA does fully regulate the procedures for filing of refund claims, and more specifically the time requirements for filing of such claims, so as to preclude the late filing sanctioned under section 2-616(b) of the Civil Practice Law ( 735 ILCS 5/2-616(b) (West 2006)).

To the extent that the Tax Code does not regulate matters of procedure, the Civil Code applies. See People ex rel. Southfield Apartment Co. v. Jarecki, 408 Ill. 266, 274 (1951) ("where the Revenue Act [the statute that formerly contained the relevant provisions of the Tax Code] is silent, * * * the Civil Practice Act and rules of court apply"); In re Application of the Cook County Collector for Judgment Order of Sale Against Lands Lots Returned Delinquent for Nonpayment of General Taxes for the Year 1987 Prior Years, 271 Ill. App.3d 12, 16 (1995) ("To the extent that the Revenue Act does not regulate matters of procedure, the Code of Civil Procedure applies"); In re Application of Rosewell, 236 Ill. App.3d 165, 168-69 (1992). Indeed, section 2-108(b) of the Civil Code provides: