With the children grown, and weary from years of trudging up and down the stairs of their Buffalo Grove duplex, Judie and Richard Goldberg recently moved to a new home that was not only more convenient and comfortable but a bargain.

For $76,000 they got 1,943 square feet of living space, all on one level, complete with a foyer, wood-burning fireplace, gobs of cabinets, a kitchen island, two pantries, a laundry room and two baths.

About the only things missing are a permanent foundation and a big tax bill.

The Goldbergs' new residence in Park City near Waukegan is one of a new generation of amenity-loaded mobile homes that are every bit as cushy as brick or frame abodes. And, thanks to a 26-year-old law that grants steep assessment discounts to mobile homes, they are considerably easier on the wallet come tax time.

The mobile-home industry is rapidly evolving from the old-fashioned rust-bucket single-wides to plush and capacious models that appeal not just to empty-nesters such as the Goldbergs but increasingly to middle-class families with many children. That is stoking a debate gathering like so many rolls of vinyl siding across Illinois.

School administrators, tax collectors and other local government officials complain that as mobile homes go upscale, their owners no longer pay their fair share for fire and police protection, education and other municipal services.

On the other side are operators of mobile-home parks who contend they don't require much in the way of town services and that mobile homes give those who otherwise couldn't afford it the dignity of owning their own place.

Enough people have complained about tax breaks for mobile homes that some state legislators are suggesting they be revoked. Last month, Secretary of State Jesse White convened a statewide Task Force on Mobile Home Taxation.

The issue is so volatile, though, that task force leaders have decided to just nibble at the edges of the problem. They are considering a proposal that would add teeth to state law so tax collectors could more easily go after mobile-home owners who fail to pay taxes.

But the task force members, who include legislators, mobile-home park owners and county treasurers, for now have decided to ignore the elephant crowding the room: the question of whether mobile-home owners pay enough taxes.

State Rep. Philip Novak (D-Bradley), co-chairman of the task force, said passing a bill that would increase taxes for mobile-home owners "would be an insurmountable task."

"You'd have thousands of senior citizens coming to Springfield and lobbying their legislators, saying, `What are you doing to us? You're forcing us out of our homes,' " predicted Novak, who said his home county of Kankakee has the most mobile homes per capita in the state. "What is the answer? I don't know what the answer is."

Technically, mobile-home owners in Illinois don't pay real estate taxes. Instead, they pay something known as the "privilege tax" that sets out a sliding scale for mobile-home taxes--starting at 15 cents per square foot for newer models and dropping to 7 1/2 cents after 15 years.

"The privilege tax hasn't kept pace with property taxes, and the value of these (mobile) homes has increased dramatically," said Tim Bramlet, president of the Taxpayers' Federation of Illinois. "You can have homes that are at least $100,000 and they're called mobile homes. Clearly, there are some inequities."

Some taxing bodies in Cook County are complaining even more loudly because state law exempts mobile-home owners in the county from the tax.

In Kankakee County, officials are so upset about the privilege tax they have denied zoning permits over the last few years to big mobile-home parks. School district officials have complained they are overwhelmed by children coming from mobile homes.

Sandridge Elementary School District 172 in Chicago Heights is one of the hardest-hit in the state. Three out of four district students live in a mobile home, said former board President Roger Sons.

That number wouldn't make any difference, except that the tax revenue generated by the average mobile home is less than one-quarter that generated by the average traditional home, Sons estimated.

State Rep. Michael Giglio (D-Lansing) wants to change that. Last month, he sent a letter to his House colleagues seeking ideas "to address the disparity."

Both sides are fond of wielding that most potent of political weapons--the elderly.

"The problem, in my opinion, results in homeowners and business owners paying more than their fair share--senior citizens throughout the state subsidizing mobile-home parks and the mobile-home park owners," Giglio said.

But Ed Zeman, vice president of Zeman Manufactured Homes, a Chicago-based firm that manages mobile-home parks, notes that older residents make up a substantial percentage of mobile-home owners. So any cut in privilege-tax benefits would hurt them as well.

That's how Leo and Mary Sauer see it. The Sauers, who live in a trailer park in Downstate Lincoln, say it will be much harder to make ends meet if their taxes increase.

Still, they say sarcastically, they'll get by.

"We always have. We grew up in the Great Depression," said Leo Sauer, 75, who also survived the Battle of Iwo Jima in World War II.

Giglio, who plans to introduce legislation in the spring to address the issue, is unmoved by such complaints. Asked if a privilege-tax hike would rob senior citizens and working-poor families of the very savings that attracted them to mobile homes, he said: "You say it's a substantial savings. I say it's a substantial unfairness. And this problem is going to get worse before it gets better because more of these parks are opening throughout the state."

And the nation. About 372,000 mobile homes were shipped last year, compared with 221,000 in 1980.

Those numbers are driven by people such as the Goldbergs, who recently moved into their double-wide in Zeman's Maple Grove Estates.

Amenities aside, low taxes were a big attraction for the couple. In Buffalo Grove they were paying $3,900 a year for a small, three-bedroom home. Though they won't know until next year, they expect their privilege tax to be just a few hundred dollars.

While the Goldbergs enjoy their new home and officials such as Giglio fume, the secretary of state's task force is trying to figure out a way to better collect privilege taxes.

Generally speaking, mobile-home parks aren't the problem. It's the trailers that are truly mobile, change owners and end up in another county without the local treasurer knowing it.

There are few effective ways to make scofflaws pay. Those who own traditional homes and owe real estate taxes can have their past-due taxes bought by someone else at a tax sale and eventually lose their home.

Tax collectors have no such stick to use against delinquent mobile-home owners. And it shows: While tax collection rates are about 98 percent for real estate taxes, they range from 50 percent to 70 percent for mobile-home taxes, Novak said.

After a recent meeting with park owners, legislators and others, county treasurers decided to poll their colleagues around the state to see if a tax sale might work for past-due mobile-home taxes. But most of those involved are skeptical that a larger solution can be found anytime soon.

Hank Spellman, owner of Tremont Park in Downstate Lincoln, where Leo and Mary Sauer live, put it simply: "At this point, I don't see something that I think would work--legally or politically."