characterization leaves open the possibility that you could i say it's a text only or a property owner in your situation could wait one year two years three years  a business or run run of the real estate that the statute says it's board without reimbursement if it's not recorded within one five years ten years if the tax code is not complied what if what if it during that period of time the person that received the tax deed has sold it to someone else in good good faith and so you have a different owner and we might have a license argument so the circumstances that we describe are very very very then that raises the question why are we in the situation and why are you in the situation that you're in it why didn't anybody bank do something when  to form a non human being cannot sign an affidavit this way the extension if that's what we want to call it was delivered and accepted by the county but g j had no right let me let me ask you what's the purpose behind extensions by the tax lien buyer and the assignee well i didn't understand i don't understand what what's the purpose why would why would anyone in that situation and that based on the language in the tax code it's either a purchaser or his or her a son eat that's can file an extension and in this case we believe one of the other  fourteen a one or twelve o three petition it is there a difference there what why should there be a difference there's a difference here the collateral tack is is a motion to attack it's a relief from the order directing they had the right so we believe that that's an admission that this was not a flat tax at least the motion for it and but the cool air because if our purchaser asked me here except it because the redemption date was not properly stock it expired on june twelfth two thousand and eight which interesting is that c c p i who received the taxes that they senate for reasons unknown to the taxpayer in this case they waited until november fourth two thousand and nine to record their date some six months after the feb twelve redemption became void in our opinion it became void on june thirteenth yes me it began june thirteenth two thousand all right but the tank period is the creation of the void of the pointless it's a ga gap was created because they failed to properly stack the next extension delivered by the saber group in this case was on july first so the gap is june twelfth to july first when the june twelfth date comes and goes the redemption period is gone forever because no tax case also in addition to section twenty one three fifty eight c which defines holder of the certificate as the person who could extract section twenty two twenty one to sixty as it relates  that the owner of the certificate of purchase shall give notice as required by the code and may extend the period of redemption as provided by section twenty one again it's the owner so getting back to the section twenty two for only only the whole the will of the certificate can attain a taxi they don't surrender it to the count as holder in reach change the primary reason why they are attacking the feb eleventh two thousand and nine court order making a finding that there be densham date expired nov twenty fifth two thousand and eight they can say all day that they are not attacking that court order but the act section twenty two eighty five is indeed the self effectuating fiat's here however is a perfect so let me ask you this that you're basically arguing errors aren't made in the court and that if an error is made tough luck he why why shouldn't they individual be allowed to challenge what is it really a finding of it except that the order but your is saying is is that why should they be not be allowed to attack the court order nine months and twenty six days after its entry finding  expired nov twenty fifth two thousand and eight in the answer is simply this you cannot attack the notices in the text the preceeding and why is the cell this is for merchantability attacks the very have been occasion tax purchasers have petitioned for tax feed and a property index number is wrong on a twenty two to ten take notice if they do not file the owner does not file or interested party in objection in the instant t x t proceeding all other allegations contained in the pleading our legal conclusion it's a legal conclusion to determine their savior or a j g or any agent of saber could  extension of period of redemption if there were indeed if a actual factual break in the judgement book in the clerk's office and there was a gap such as cert then indeed twenty to eighty five would be in operation because you would not have recorded within the last expiration date but in this case the expiration date as a matter of a conclusive fact was november two thousand and five excuse me november twenty  thousand and eight and the tax teacher who's quoted within one year so the text he was perfect it let me stop you there because i think your say that under certain the court has a right reasonable its use has been afforded to the court yes you're right redemption first was an effective way to properly when they had mailed the amount in and there was ample time for them to correct that but they did nothing then at that time they could attack the very notices that they're attempting to do toto day but they sat on their rights and when you sit on your rights your availability shifts to attack attacks let me just make clear from for myself  what is your argument that the initial extension of the redemption period was perfectly fine was it because it filed that j g was no longer the lead holder they had it assigned to say that's correct that's correct but your but you're really not taking a position as to why that's statutory interpretation is the expressed language of c actually and that all other rules are support nay and in this case section twenty one three eighty five express the say that  in this case that's the very issue in contention the tax purchaser is that there's no harm no foul here this isn't like a stranger went in filed a notice of extension every definition period and moreover it's a matter of public what's your best case for the practice issue that you could be the setting or or the perch and could you repeat that your honor the best case for west case that you have that that would show that they can say that hey we need to talk about purchaser asked me but really what they're doing is they're saying that the twenty to forty court order finding that the expiration of the retention day november twenty fifth two thousand and eight is not valid they cannot attack that court order nine months in twenty six days after it's issuance if you allow this where it is that where it is a staff can somebody come in in a challenge to tax the perceiving with a pin number or a certificate wrong on a notice nine months in twenty six days richard billeted you have tax heat in the public policy behind that is imperative we need the money in the coffers to pay the bills and when people do not pay their taxes on time which they have a duty to be aware of and deal then they must be sold in unfortunately it is a harsh reality that if you do not read email after be serving notice three times after being told by a clerk that you sent it late and you do not be until year and almost six months later to come in and now say wait a minute there be densham date is not right and it's void you've sat on your rights those rights have shifted did in the search case of word order can be attacked any time in this case it's a boy deed that we're attacking and it can be attacked any time this concept of collateral attack under twenty to forty five because when we present a motion to avoid a tax if twenty two forty five prevents us from examining an error or impropriety in the tax deed here in the fine then when could one use twenty two it would become superfluous you need twenty to eighty five is a specific narrowly tailored statute that almost every tax buyer co only the holder can petition the tax the court only the holder can obtain a court ordered taxi it's absurd to think that either one of them can do it only the holder can't it's the simple i don't think it's a strict interpretation at all i think it's the right interpretation because if if i did say is that the right call to sink it it's a strict interdicted which yes the strict it's a strict interpretation because the tax  is strict because one in this case the property was lost for three hundred forty seven dollars tax the tax purchaser fell to comply with this tax code because g j having no authority court's attention to the quote in the circuits where the court indicated that the primary purpose of the tax provisions of the property tax code is to course tax the link with owners to pay their taxes it the merchant ability of taxed again as i stated earlier this twenty two eighty five argument has appeared one time in forty a taxi for this court this is a specific narrow statute that professional tax purchasers follow and know that their deeds must be recorded because the tax purchaser ran afoul if lost everything