However, in the recent Washington case of Krops v. Jacobson, a tax title, procured through a judgment in foreclosure proceedings for delinquent taxes, was set aside as void, even though the taxes had not been paid. The reason assigned was that the foreclosure had been caused by the failure of the county treasurer to note upon the receipt given in payment for current taxes that certain back taxes were due. To the legislative direction that there shall be two exceptions to the conclusive effect of a judgment in tax foreclosure proceedings, the court has added a third—frustration of the taxpayer in the payment of his taxes by the public officer.
L. R. Bonneville, Jr.,
How Secure Is Your Tax Foreclosure Title?,
23 Wash. L. Rev. & St. B.J.
Available at: https://digitalcommons.law.uw.edu/wlr/vol23/iss2/5