main contention which is to use their terminology one would have to chip reason at the door to read the statute as it is written in that there has to be some materiality requirement writ into the bankruptcy petition had actually been dismissed at the time of the sale that they couldn't apply because there was no time limit on how long and to the larger point about whether this is something logical with us as something that makes good sense as a statute they went on to say the legislature based on the plane restrict websites are based on the records that the county keeps in their offices these property characteristic cards so it is information that the county compiles and publishes as par good argument when you think i don't think so because state statute can't be circumvented by the county it's all saying well you know even if this may be it here or we're going to find it is not in here or they can't circumvent state all with their own disclaimer there are publishing information about property and again i think it in terms of circumventing of state laws by their own disclaimers of definition of what is or what is not in error so i really don't think that argument is persuasive here thank you and  without text buyers descaler sale doesn't happen the county doesn't recoup any delinquent tax money in this county here a provision is a protection for tax buyers there they're not assured respondents heard but i think that the court should take a broader view of this the actu and not allow what could be honestly viewed as bad facts to make bad law because you have to look at this case in terms of the overall functioning of this property tax code i mean this is an intricate statute of the been around for decades it's been very successful in recouping money for the county  there's materials out there we didn't cite them with the high degree to which properties are deemed him and part of it is allowing deck tax buyers a potential house and there's really no harm is it fair to say that most taxpayers do go out and look at the property to make sure that it's what they expected to be i take pictures of it themselves so they know who to contact if there isn't a sale station or a program volved or an o you might not know what they're wise i mean is that a fair statement i don't know that it is justice and based on my limited personal experience mainly with the council who brought you into this cases of these taxpayers are buying hundreds of the certificate of sale i don't recall that they are getting that it was incorrect it's not really  have been frustrated or defeated or are at risk of some economic harm related to the sale we don't have any of those circumstances in this case the assessor calling dulls an avenue instead of a road did not frustrate any expectations by the tax prior and the test fire is not ever is given any economic harm as a result of the sale the taxpayer was not misled in this case especially when there is no evidence of adult and avenue  the main question this before this court is whether an error by the assessor can be used to vacate a tag sale when that hearing has no connection by no relationship to that sale itself or the answer the question is  and for each of those there is a clear connection between the air that's alleged and the and the tax sale for example of your property where the taxes were paid prior to sale and then since the circuit court did not have jurisdiction  of these types of cases we have it here that is logically serving as a basis to vacate a taxi there's a rational nexus between the here in the sale itself and the county or provision at issue here it sits in the middle of all those other grounds for sale in here so it has to be read within that context and from then it's clear that the legislature intended an era by a county official to have some connection to the tax sale to justify settings sales  were the assessor it's a case where a check her property owner had applied to the assessor's office st certificate over here and when that happens he says are supposed to timely process the application say sure because their property never should have been on the tax sale to begin with and there was a defect in the process that's related to an action by a county official and you can have another instance where let's say for example though the records of a county official are here insofar as they list the wrong amount of taxes that are due on a property and that is that is often for sale so it's so either more or less that is actually the mother barberin that could be material because it's affecting other property owners redemption rates as to how much they'll have to pay when it comes time to redeem those are all material to the tax doctrine involve material harms her defects we don't let buyers unwind sales or claim damages when you have defects or errors that are immaterial so the same should be true for the sale here statute because it serves as an exception to legislature did not attend a taxpayer who simply does not want to pursue a deed on a property just scour county records looking for any kind of inconsistency or hear within those documents solely for the purpose of setting aside their purchase and that appears to be what happened in this case there is no evidence that the taxpayer knew that the assessor described dalton as an avenue until it went looking for a reason to vacate its purchase rely on tax sales who fund very important government services the funders schools they fund public hospitals so it's almost impossible to imagine that the legislature would treat tax sale so lightly that they could be vacated anytime there's any here because of this you know how vital this is for collecting revenues for the county well i think number one the fact that this city is huge has been around for decades and it's been very successful shows that last two and a half years and even though yes in this particular instance they would have to refund them money they don't lose it necessarily because the property goes back on the scavenger sale may have an opportunity to sell it again so i think in terms of the statutory scheme the legislature has made a clear choice oh hole wyoming this to happen to encourage as many tax buyers as possible into the scavenger sale the overall effect of which is wildly successful in recruiting a lead when taxes and raising money for the county so that in one dollar case or another money has to be refunded yes in this case it's a substantial amount of money it shouldn't alter the application both the stiff shoot as written because that could be a as i mentioned earlier raise uncertainty among tax buyers as to what their real risk is here they're already taking a risk as to whether they'll get their investment back or not and i think the legislature based on the clear language of the five made the decision you know we're going to have this