Pung v. Isabella County · ¶83

Historically, tax foreclosure sales were subject to strict limits. These limits, among other things, protected the property rights of the homeowner and helped to avoid a conflict between tax foreclosures and the Takings Clause. “[G]reat strictness [was] required; and . . . the provisions of law preparatory to and authorizing such sales,” had to be “punctiliously complied with.” T. Cooley, Law of Taxation, Including the Law of Local Assessments 325 (1876) (Cooley) (internal quotation marks omitted). Tax foreclosure sales, it was said, “deserve no indulgence from the court,” and “he who claims under a forfeiture, must shew that the law has been exactly complied with.” Wilsons v. Bell, 34 Va. 22, 24 (1836).

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