Difenderfer v. Carbon County Tax Claim Bureau

In Difenderfer v. Carbon County Tax Claim Bureau, 789 A.2d 366 (Pa. Cmwlth. 2001), a county tax claim bureau presented a USPS certificate of mailing as "proof of mailing" under the RETSL. After the bureau received the certified mail receipt as unclaimed, it sent a ten-day notice to the property owner by first-class mail with a USPS certificate of mailing. However, because the postmark on the certificate was illegible and the bureau representative did not specifically testify to when the notice was mailed, this court affirmed the vacation of the tax sale. Id. at 367-68. The Court did not, however, address the question of what type of proof of mailing is required under section 602(e)(2).