In Goggins v. Leo, 849 S.W.2d 373, 377 (Tex. App.--Houston [14th Dist.] 1993, no writ), Leo purchased property at a tax sale and brought a forcible detainer action against the former owner's tenant. Goggins, 849 S.W.2d at 375.
The tenant appealed the adverse judgment and argued, inter alia, that Leo failed to prove up title. Id. at 377.
The Court explained that one who purchases a property at a tax sale "need not prove up title, but need only show sufficient evidence of ownership to demonstrate a superior right to immediate possession." Id.