In Dimondale v. Grable, 240 Mich. App. 553, 618 N.W.2d 23 (2000), the grantee of a purchaser of land at an IRS tax sale filed a petition to quiet title to the property. The delinquent taxpayer answered that the tax sale was invalid because the IRS failed to comply with the notice requirements of 6335. The trial court granted summary judgment to the grantee, but upon review, the Michigan Court of Appeals reversed, and remanded for the trial court to enter summary judgment in favor of the delinquent taxpayer. The appellate court recognized that under 6339(b), a tax deed is valid on its face because the deed is prima facie evidence of the facts stated within it. But while the tax deed contained a statement that the tax sale was conducted in compliance with the statutory notice requirements in Dimondale, the delinquent taxpayer rebutted this deed's assertions by showing inadequate notice, a claim which the grantee did not disprove with contrary evidence. Therefore, the court in Dimondale held that the statement in the tax deed that the IRS complied with all relevant statutory provisions had no effect on the court's quiet title decision. The Michigan court held that "'"the burden of showing literal compliance with statutes governing the sale of land for taxes is upon the claimant upon the tax sale."'" 240 Mich. App. at 568, 618 N.W.2d at 31.