Citimortgage, Inc. v. KDR Investments, LLP

In Citimortgage, Inc. v. KDR Investments, LLP, 954 A.2d 755 (Pa. Cmwlth. 2008), the property owner had actual notice of a tax sale twelve days prior to the sale. However, noting that, by statute, a tax claim bureau must provide owners thirty days prior notice of a tax sale, this court held that the tax sale was void because the property owner did not have timely actual notice. Moreover, the Court has stated that a property owner must have actual notice "in sufficient time for her to react to prevent the sale or protect her interests." Casaday v. Clearfield County Tax Claim Bureau, 156 Pa. Commw. 317, 627 A.2d 257, 259 (Pa. Cmwlth. 1993); See also In re Tax Sale of Real Property Situate in Paint Township, Somerset County, 865 A.2d 1009 (Pa. Cmwlth. 2005) (stating that a property owner's actual knowledge of a tax sale must be in time to protect her due process rights).