Parkton Enterprises, Inc. v. Krulac

In Parkton Enterprises, Inc. v. Krulac, 865 A.2d 295 (Pa. Cmwlth. 2005), a sheriff's sale of property in a foreclosure was followed closely in time by an upset tax sale. There, Parkton bought the property at a sheriff's sale on September 4, 2002, and its deed was recorded on September 25, 2002. Because of unpaid taxes, an upset tax sale was held on September 26, 2002, where the Krulacs bought the property. Parkton was not notified in advance of the tax sale. The Court affirmed the trial court's decision to set aside the tax sale. The Court explained that the Bureau "failed to make a reasonable effort to discover the identity of the new owner of the Property, i.e., Parkton," even though it knew that the property would be sold at a sheriff's sale shortly before the tax sale. Id. at 299.