The state of Illinois says two companies that belong to the founder of the Jimmy John’s sandwich chain owe the state more than $1.4 million in taxes on a pair of corporate jets.

Attorneys for Jimmy John Liautaud  say the state isn’t properly applying the tax code.

Liautaud has been an outspoken critic of Illinois’ income tax. In 2011 he threatened to move his company’s headquarters from Champaign to Florida over Gov. Pat Quinn’s decision to raise the tax.