The substantial volume of tax sale decisions from appellate courts continues. A tax sale was voided where the tax claim bureau failed to take reasonable steps to notify the owner when service was unsuccessful. 777 L.L.P. v. Luzerne County Tax Claim Bureau, Appeal of Mannino, No. 925 C.D. 2014 (Pa. Commw. Mar. 30, 2015). In another case, a tax sale was voided where the tax claim bureau did not advise the taxpayer of her right to enter into a payment plan, once she had paid more than 25 percent of the liability before the sale. In re Sale of Tax Claim Bureau, Appeal of Joann P. Vignola, No. 718 C.D. 2014 (Pa. Commw. Mar. 30, 2015). The court distinguished a case in which a taxpayer had paid 25 percent of the delinquency after the upset sale. In a third case, the court rejected the argument of a mortgagee that the property was occupied by the taxpayer based on the facts. Brentwood Borough School District v. HSBC Bank USA, N.A., No. 2346 C.D. 2013 (Pa. Commw. Mar. 24, 2015). In a fourth case, the court remanded an appeal from a tax sale for an evidentiary hearing whether an individual was an owner of the property. In re Tax Parcel Nos. J6-7-1-0520, Appeal of Edwin Filchner, No. 2097 C.D. 2013 (Pa. Commw. Mar. 9, 2015) (unreported).

The high volume of decisions suggests that it may be time for the General Assembly to review the tax sales statutes.