Little Appeal

18 Pa. D. & C.3d 19, 1981 Pa. Dist. & Cnty. Dec. LEXIS 473
CourtPennsylvania Court of Common Pleas, Adams County
DecidedMarch 24, 1981
Docketno. 80-S-618
StatusPublished
Cited by1 cases

This text of 18 Pa. D. & C.3d 19 (Little Appeal) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Adams County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Little Appeal, 18 Pa. D. & C.3d 19, 1981 Pa. Dist. & Cnty. Dec. LEXIS 473 (Pa. Super. Ct. 1981).

Opinion

SPICER, P.J.,

We have before us for disposition exceptions and objections filed to two sales conducted by the Adams County Tax Claim Bureau for delinquent taxes. The exceptants are Paul D. Little and Emma J. Little who were the owners of an improved residential property. They were classified as an owner occupant under the act, infra, section 102. Phillip Sheely and Norma Sheely were the owners of unimproved real estate.

[20]*20We will refer to the parties by their last names hereafter and the Adams County Tax Claim Bureau as the bureau. The cases involve notice requirements under the Real Estate Tax Sales Law of July 7, 1947, P.L. 1368, 72 P.S. §5860.101 et seq., as most recently amended July 10, 1980, P.L. 417. We will refer to this act as the act.

We held a hearing in these cases and have previously ruled on all exceptions and objections except those pertaining to posting of the premises. We will discuss each case separately.

APPEAL OF LITTLE

The constable who was posting notices for the bureau went to the Little property on August 5, 1980. In order to save the Littles embarrassment he did not post notice of the tax sale. Instead, he went to the kitchen door, knocked, and when Mrs. Little answered, handed the notice to her.

Later, on August 11, 1980, the sheriff served Mr. Little personally with a notice in proper form. The tax sale was conducted September 8, 1980.

Under section 601a of the act, effective July 10, 1980, notice to the Littles was required to be given personally at least ten days before sale by the sheriff or his designee. Posting was also required under provisions of section 602.

The provisions of the act have been amended several times. Reading cases which appear pertinent, one is apt to discover that it deals with different notice requirements. Prior to 1959, posting was required only if mailed notice was not delivered. Posting as an additional form of notice was added in 1959.

It would seem clear, however, that failure to post [21]*21the property invalidates the sale. The Commonwealth Court (panel) held that failure to post invalidated a sale when an owner had received notice by mail: In re Sale of Properties by Indiana County Tax Claim Bureau for Unpaid Tax Claims: Wanchisn, 22 Pa. Commonwealth Ct. 147, 348 A. 2d 440 (1975). That court said that there must be strict compliance with the notice provisions of the act.

In another case, Judge Morgan, writing for Dauphin County Court, said, “It has been clearly stated that the Real Estate Tax Sale Law makes all three types of notice

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Related

Hunter v. Washington County Tax Bureau
729 A.2d 142 (Commonwealth Court of Pennsylvania, 1999)

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Bluebook (online)
18 Pa. D. & C.3d 19, 1981 Pa. Dist. & Cnty. Dec. LEXIS 473, Counsel Stack Legal Research, https://law.counselstack.com/opinion/little-appeal-pactcompladams-1981.