CROCKETT, Justice:
Plaintiff sues asserting fee ownership of certain lots in the northeast of Salt Lake City as against the defendants, who claim under a county auditor’s deed issued pursuant to a May sale based on failure to pay taxes. Salt Lake County was named as a party defendant, and filed a disclaimer. It was shown that the May sale was not conducted by the county auditor (or his [381]*381deputy)1 as required by statute,2 but by Mr. Wendell Hibler, an employee in that office. In accordance with the holding of this court in a case of similar facts, Page v. McAfee,3 the trial court ruled that the defendants had not acquired a valid title; and gave judgment for the plaintiff, conditioned upon its reimbursing the defendants for the amount of taxes, penalties and interest thereon. Defendants appeal.
The ruling of the Page case would seem to be sufficient justification for the trial court’s ruling and for the affirmance of the judgment. However, in addition to questioning the correctness of the ruling in that case, defendants make other arguments upon which we comment.
They contend: that under our statutes relating to tax proceedings, after the sale on January 15th for delinquent taxes,4 the property owner (plaintiff) has a right of redemption only until April 1st of the fourth year,5 and that if he fails to redeem by that date the title to the property then vests in the county; and that the plaintiff has no further ownership or interest therein. Wherefore, defendants assert that as purchasers from the county at the May sale, and/or as beneficiaries of the county’s disclaimer, they should prevail over the plaintiff’s claim. In support of this argument they cite cases containing language so indicating the county’s ownership after the redemption period has expired.6
We are cognizant of the language of those cases. But even though they speak about ownership by the county, they also recognize that the fee owner (plaintiff) does continue to have some interest in his property and a method of restoring full ownership to himself. In any event, that is the necessary, and the only reasonable conclusion that can be derived from an examination of our statutes. If the owner were divested of all interest in his property, and it was completely vested in the county, the owner would have no better standing than any other purchaser at the May sale. But such is not the fact.
With respect to the May sale, Section 59-10-64 provides in substance that the property shall be sold to the bidder who will pay the full amount of the taxes, penalties, interest and costs for the smallest portion of the entire parcel; and that if it is sold for a portion, the remaining part of the property “shall be deemed to have been redeemed by the owner thereof.” It is plain to be seen that if the owner is willing to pay the amount due the county at the [382]*382May sale, he can be restored to his ownership, or in effect, “redeem” his property. He is free to continue to bid that amount for a smaller and smaller fraction of the property than any other purchaser, because he will get both that fraction, and also all that is left of the property, for that amount.
Corroborating the idea that the owner continues to have some interest in his property until there is a valid May sale are these provisions of Subsection (6) of Section 59-10-64 relating to that sale:
Any property offered for sale as aforesaid and for which there is no purchaser shall be struck off to the county by the county auditor, who shall publicly declare substantially as follows: “All property here offered for sale and which has not been struck off to a private purchaser is hereby struck off and sold to the county of-, and I hereby declare the fee simple title of said property to be vested in said county.” The county auditor shall thereupon make an endorsement opposite each of the entries . . . [describing the entry], The fee simple title to said property shall thereupon vest in the cbunty.
While there may be some overlapping of the language of this statute with the idea that the owner is required to redeem prior to April 1st, the emphasized language, that after the May sale the “property shall thereupon vest in the county” plainly imports that there remained in the property owner (plaintiff) some ownership interest therein. Otherwise there would be nothing left to “thereupon vest in the county.”
From the foregoing it seems incontrovertible that the fee owner has an interest in his property which he can regain by payment of the amount due the county; and it is not of any great moment what terminology is used, right of redemption, reversion, or whatever.
In supplement of defendants’ argument that the entire ownership of the property vested in the county prior to the May sale, which we have just stated is not well-founded, defendants claim some advantage to themselves in the disclaimer filed by the county; and urge that even if their own deed be invalid, the title is nevertheless in the county, and not in the plaintiff. We do not see how these arguments help the defendants. The disclaimer filed by the county in this action does not redound particularly to the benefit of either the defendants or the plaintiff; conversely, it is just as much to the benefit of the one as the other. It simply gets the county out of the case, and leaves the question to be determined: who has the superior claim of title between the plaintiff and defendants. That comes down to this proposition: as pointed out above, the plaintiff owner has the underlying owner[383]*383ship in the property, which can be reclaimed until there is a valid May sale; and this claim of ownership is superior to any asserted claim of the defendants, who have failed to acquire a valid title because of fatal defect in the taxing procedure.
We agree that there are many areas in the law where the status and the acts of de facto officers are deemed valid as to third parties.7 But as in most situations, there is another side of the coin. There are also to be considered the difficulties which may sometimes result from taking for granted that any person who assumes to have authority to perform official acts and does them should be deemed to have such authority as a de facto officer. This is particularly true when it is asserted and relied on as part of the “taxing-forfeiture” procedure where the rule of strictissimi juris applies.
Whenever rules appear to overlap it is the responsibility of the court to determine and to apply that rule which is the more fundamental in that it best harmonizes with and carries out the purpose and policy of the law. In that regard it is appropriate to have in mind that the main purpose of all of the taxing procedures is to enforce the payment of taxes, and not the confiscation of property. Although it is true that confiscation may be the final and drastic measure, it should result only as the ultimate necessity to the accomplishment of the main objective.
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CROCKETT, Justice:
Plaintiff sues asserting fee ownership of certain lots in the northeast of Salt Lake City as against the defendants, who claim under a county auditor’s deed issued pursuant to a May sale based on failure to pay taxes. Salt Lake County was named as a party defendant, and filed a disclaimer. It was shown that the May sale was not conducted by the county auditor (or his [381]*381deputy)1 as required by statute,2 but by Mr. Wendell Hibler, an employee in that office. In accordance with the holding of this court in a case of similar facts, Page v. McAfee,3 the trial court ruled that the defendants had not acquired a valid title; and gave judgment for the plaintiff, conditioned upon its reimbursing the defendants for the amount of taxes, penalties and interest thereon. Defendants appeal.
The ruling of the Page case would seem to be sufficient justification for the trial court’s ruling and for the affirmance of the judgment. However, in addition to questioning the correctness of the ruling in that case, defendants make other arguments upon which we comment.
They contend: that under our statutes relating to tax proceedings, after the sale on January 15th for delinquent taxes,4 the property owner (plaintiff) has a right of redemption only until April 1st of the fourth year,5 and that if he fails to redeem by that date the title to the property then vests in the county; and that the plaintiff has no further ownership or interest therein. Wherefore, defendants assert that as purchasers from the county at the May sale, and/or as beneficiaries of the county’s disclaimer, they should prevail over the plaintiff’s claim. In support of this argument they cite cases containing language so indicating the county’s ownership after the redemption period has expired.6
We are cognizant of the language of those cases. But even though they speak about ownership by the county, they also recognize that the fee owner (plaintiff) does continue to have some interest in his property and a method of restoring full ownership to himself. In any event, that is the necessary, and the only reasonable conclusion that can be derived from an examination of our statutes. If the owner were divested of all interest in his property, and it was completely vested in the county, the owner would have no better standing than any other purchaser at the May sale. But such is not the fact.
With respect to the May sale, Section 59-10-64 provides in substance that the property shall be sold to the bidder who will pay the full amount of the taxes, penalties, interest and costs for the smallest portion of the entire parcel; and that if it is sold for a portion, the remaining part of the property “shall be deemed to have been redeemed by the owner thereof.” It is plain to be seen that if the owner is willing to pay the amount due the county at the [382]*382May sale, he can be restored to his ownership, or in effect, “redeem” his property. He is free to continue to bid that amount for a smaller and smaller fraction of the property than any other purchaser, because he will get both that fraction, and also all that is left of the property, for that amount.
Corroborating the idea that the owner continues to have some interest in his property until there is a valid May sale are these provisions of Subsection (6) of Section 59-10-64 relating to that sale:
Any property offered for sale as aforesaid and for which there is no purchaser shall be struck off to the county by the county auditor, who shall publicly declare substantially as follows: “All property here offered for sale and which has not been struck off to a private purchaser is hereby struck off and sold to the county of-, and I hereby declare the fee simple title of said property to be vested in said county.” The county auditor shall thereupon make an endorsement opposite each of the entries . . . [describing the entry], The fee simple title to said property shall thereupon vest in the cbunty.
While there may be some overlapping of the language of this statute with the idea that the owner is required to redeem prior to April 1st, the emphasized language, that after the May sale the “property shall thereupon vest in the county” plainly imports that there remained in the property owner (plaintiff) some ownership interest therein. Otherwise there would be nothing left to “thereupon vest in the county.”
From the foregoing it seems incontrovertible that the fee owner has an interest in his property which he can regain by payment of the amount due the county; and it is not of any great moment what terminology is used, right of redemption, reversion, or whatever.
In supplement of defendants’ argument that the entire ownership of the property vested in the county prior to the May sale, which we have just stated is not well-founded, defendants claim some advantage to themselves in the disclaimer filed by the county; and urge that even if their own deed be invalid, the title is nevertheless in the county, and not in the plaintiff. We do not see how these arguments help the defendants. The disclaimer filed by the county in this action does not redound particularly to the benefit of either the defendants or the plaintiff; conversely, it is just as much to the benefit of the one as the other. It simply gets the county out of the case, and leaves the question to be determined: who has the superior claim of title between the plaintiff and defendants. That comes down to this proposition: as pointed out above, the plaintiff owner has the underlying owner[383]*383ship in the property, which can be reclaimed until there is a valid May sale; and this claim of ownership is superior to any asserted claim of the defendants, who have failed to acquire a valid title because of fatal defect in the taxing procedure.
We agree that there are many areas in the law where the status and the acts of de facto officers are deemed valid as to third parties.7 But as in most situations, there is another side of the coin. There are also to be considered the difficulties which may sometimes result from taking for granted that any person who assumes to have authority to perform official acts and does them should be deemed to have such authority as a de facto officer. This is particularly true when it is asserted and relied on as part of the “taxing-forfeiture” procedure where the rule of strictissimi juris applies.
Whenever rules appear to overlap it is the responsibility of the court to determine and to apply that rule which is the more fundamental in that it best harmonizes with and carries out the purpose and policy of the law. In that regard it is appropriate to have in mind that the main purpose of all of the taxing procedures is to enforce the payment of taxes, and not the confiscation of property. Although it is true that confiscation may be the final and drastic measure, it should result only as the ultimate necessity to the accomplishment of the main objective. It is evident that that is the intent of our statutes; and consistent therewith it is also the practically universal rule of decisional law: that the sovereign (taxing authority) is required to follow procedures prescribed by law with accuracy and particularity before it can forfeit one’s property.8 In the Page case9 we held that that standard was not met by sale of the property by one not authorized to do so; and we are not inclined to change that position.
In accordance with our discussion herein, we are not persuaded that the trial court was in error in its findings and judgment in favor of the plaintiff, conditioned upon its doing equity by making reimbursement to the defendants of all taxes, penalties, and interest paid by them. [All emphasis added.]
Affirmed. Costs to plaintiff (respondent) .
CALLISTER, C. J., and HENRIOD, J., concur.