IN THE COMMONWEALTH COURT OF PENNSYLVANIA

In Re: Upset Sale, Tax Claim Bureau :

of Tioga County Control No. 00014306 :

(Joleen George) :

: No. 908 C.D. 2022

Appeal of: Joleen R. George : Submitted: September 11, 2023

BEFORE: HONORABLE CHRISTINE FIZZANO CANNON, Judge

HONORABLE STACY WALLACE, Judge

HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION 

BY JUDGE FIZZANO CANNON FILED: October 20, 2023

Joleen R. George (Appellant) appeals the July 21, 2022 order (Trial 

Court Order) of the Court of Common Pleas of Tioga County (Trial Court) 

overruling Appellant’s Amended Objections/Exceptions to Tax Sale Held 

September 24, 2021. Upon review, we affirm.

I. Background and Procedural Posture

On September 24, 2021, the Tioga County Tax Claim Bureau (Bureau) 

conducted an upset tax sale of properties within Tioga County with delinquent 2019 

real estate taxes (Upset Sale) at which Appellant’s mobile home located at 1097 Pitts 

Road, Mansfield (Property),1 was sold. Thereafter, Appellant filed objections to the 

1 The parcel of land on which the Property is situated is a tract of approximately 260-290 

acres owned jointly by Appellant, her mother, and her sister. See Notes of Testimony, April 28, 

2022 (N.T. 4/28/2022) at 30; Reproduced Record (R.R.) at 154a; see also Application for 
2

Upset Sale followed by amendments to the objections (collectively, Amended 

Objections),2in which Appellant claimed that the Bureau failed to comply with the 

notice requirements of Section 602 of the Real Estate Tax Sale Law (RETSL),

3 72 

P.S. § 5860.602, in that required notices were sent to the incorrect address and her

signature on the return receipt was a forgery. See Amended Objections, R.R. at 8a9a. The Trial Court conducted a hearing on the Amended Objections on April 28, 

2022. See Notes of Testimony, April 28, 2022 (N.T. 4/28/2022), R.R. at 122a-63a. 

On July 21, 2022, the Trial Court entered an order overruling the Amended 

Objections. See Trial Court Order, R.R. at 115a. The instant appeal followed.

II. Issues

On appeal,

4 Appellant claims that the Trial Court erred by refusing to 

set the Upset Sale aside where the Bureau sent the statutorily required notices to an 

address where Appellant no longer received mail, the first statutorily required notice 

Homestead, R.R. at 114a. At the time of the Upset Sale, Appellant was the title owner of the 

Property. See Report of Title For Real Estate, R.R. at 78a.

2 Although the Trial Court did not file the Decree Nisi regarding the Upset Sale in this 

matter until November 17, 2021, Appellant originally filed her “Objections/Exemptions to Tax 

Sale Held September 24, 2021” (Objections) on October 28, 2021, and her “Amended 

Objections/Exceptions to Tax Sale Held September 24, 2021” (Amended Objections) on 

November 8, 2021. See Decree Nisi, R.R. at 7a; Objections, R.R. at 3a-6a; Amended Objections, 

R.R. at 8a-12a. The Tioga County Tax Claim Bureau (Bureau) filed its “Answer to Amended 

Objections/Exceptions to Tax Sale Held September 24, 2021” (Answer) on February 25, 2022. 

See Answer, R.R. at 12a-44a.

3 Act of July 7, 1947, P.L. 1368, as amended, 72 P.S. §§ 5860.101-5860.803.

4

“Our review is limited to determining whether the trial court abused its discretion, clearly 

erred as a matter of law, or rendered a decision unsupported by the evidence.” In re 1999 Upset 

Sale of Real Est., 811 A.2d 85, 87 n.1 (Pa. Cmwlth. 2002).
3

was signed for by Appellant’s mother, and Appellant’s signature on the second 

statutorily required notice was allegedly forged. See Appellant’s Br. at 4, 13-24.

III. Discussion

Initially, we note that “[t]he purpose of tax sales is not to strip the 

taxpayer of [her] property but to insure the collection of taxes.” Husak v. Fayette 

Cnty. Tax Claim Bureau, 61 A.3d 302, 312 (Pa. Cmwlth. 2013). The property owner 

notice provisions of Section 602 of the RETSL, 72 P.S. § 5860.602,5 are at issue in 

the instant matter. Regarding Section 602 of the RETSL, this Court has explained:

5 Section 602 of the RETSL provides, in pertinent part:

(a) At least thirty (30) days prior to any scheduled sale the bureau 

shall give notice thereof, not less than once in two (2) newspapers 

of general circulation in the county, if so many are published therein, 

and once in the legal journal, if any, designated by the court for the 

publication of legal notices. Such notice shall set forth (1) the 

purposes of such sale, (2) the time of such sale, (3) the place of such 

sale, (4) the terms of the sale including the approximate upset price, 

(5) the descriptions of the properties to be sold as stated in the claims 

entered and the name of the owner.

(b) Where the owner is unknown and has been unknown for a period 

of not less than five years, the name of the owner need not be 

included in such description.

(c) The description may be given intelligible abbreviations.

(d) Such published notice shall be addressed to the “owners of 

properties described in this notice and to all persons having liens, 

judgments or municipal or other claims against such properties.”

(e) In addition to such publications, similar notice of the sale shall 

also be given by the bureau as follows:

(1) At least thirty (30) days before the date of the sale, by United 

States certified mail, restricted delivery, return receipt requested, 

postage prepaid, to each owner as defined by this act.
4

In all tax sale cases, the tax claim bureau has the burden of 

proving compliance with the statutory notice provisions. 

Section 602 requires three different forms of notice to 

property owners prior to an upset tax sale: publication, 

posting, and mail. If any of the three types of notice is 

defective, the tax sale is void. Notwithstanding our 

mandate to strictly construe the notice provisions of the 

law, the notice requirements of Section 602 of the 

[RETSL] are not an end in themselves, but are rather 

intended to ensure a property owner receives actual notice 

that his or her property is about to be sold due to a tax 

delinquency. However, strict compliance with the notice 

requirements of Section 602 is not required when the 

[b]ureau proves that a property owner received actual 

notice of a pending tax sale.

(2) If return receipt is not received from each owner pursuant to the 

provisions of clause (1), then, at least ten (10) days before the date 

of the sale, similar notice of the sale shall be given to each owner 

who failed to acknowledge the first notice by United States first 

class mail, proof of mailing, at his last known post office address by 

virtue of the knowledge and information possessed by the bureau, 

by the tax collector for the taxing district making the return and by 

the county office responsible for assessments and revisions of taxes. 

It shall be the duty of the bureau to determine the last post office 

address known to said collector and county assessment office.

(3) Each property scheduled for sale shall be posted at least ten (10) 

days prior to the sale.

(f) The published notice, the mail notice and the posted notice shall

each state that the sale of any property may, at the option of the 

bureau, be stayed if the owner thereof or any lien creditor of the 

owner on or before the actual sale enters into an agreement with the 

bureau to pay the taxes in instalments, in the manner provided by 

this act.

72 P.S. § 5860.602(a)-(f).
5

In re Consol. Reps. & Return by Tax Claims Bureau of Northumberland Cnty. of 

Props. (Appeal of Neff), 132 A.3d 637, 644-45 (Pa. Cmwlth. 2016) (internal 

citations, footnote, and quotation mark omitted). Accordingly, where property is to 

be exposed to an upset tax sale, Section 602 of the RETSL requires that the Bureau 

must first provide the property owner notice by publication, mail, and posting. 72 

P.S. § 5860.602. “If any method of notice is defective, the tax sale is void.” Krawec 

v. Carbon Cnty. Tax Claim Bureau, 842 A.2d 520, 523 (Pa. Cmwlth. 2004).6

Here, at the hearing on the Amended Objections, the Bureau presented 

the testimony of Joshua Zeyn, the Director of Tax Claims and Chief Assessor of 

Tioga County,

7 whose testimony established the following. See N.T. 4/28/2022 at 

4-28; R.R. at 128a-52a. On February 1, 2020, the Bureau sent a Notice of Return 

and Claim, which is a delinquent tax notice,

8

regarding the Property’s unpaid 2019 

real estate taxes (February 2020 Notice of Return and Claim) via certified mail to 

Appellant at 1097 Pitts Road, Mansfield, the Property’s mailing address from the 

6 We note that, where a property subject to an upset sale is occupied by the property owner,

Section 601(a)(3) of the RETSL requires an additional notice of the tax sale to be personally served 

on the owner-occupant. See 72 P.S. § 5860.601(a)(3). As there is no allegation that Appellant 

was an owner-occupier of the Property herein, the additional notice requirement of Section 

601(a)(3) plays no part in the instant matter.

7 Mr. Zeyn has been the Bureau’s Chief Assessor since 2020, having acted as Assistant 

Assessor for the 10 years prior. See N.T. 4/28/2022 at 4; R.R. at 128a. Mr. Zeyn is responsible 

for the day-to-day operations of both the Bureau and the Tioga County’s Assessment Office and 

is involved in Tioga County’s tax sale process. See N.T. 4/28/2022 at 4-5; R.R. at 128a-29a.

8 Mr. Zeyn explained that tax bills go out in March and July every calendar year and that 

the previous year’s uncollected taxes are returned to the Bureau for collections starting on January 

1st of the following year. See N.T. 4/28/2022 at 5; R.R. at 129a. The Bureau typically sends 

landowners delinquent tax notices containing tax balances and payment options at the beginning 

of February of the following year. See id.
6

Bureau’s tax duplicate book9 and previously provided to the Bureau on a Mobile 

Home Tax Release form transferring the Property to Appellant from Sylvia Wilcox, 

Appellant’s grandmother. See N.T. 4/28/2022 at 6-8; R.R. at 130a-32a. Appellant’s 

mother, Lucille Vandergrift, signed for the delivery of the February 2020 Notice of 

Return and Claim. See N.T. 4/28/2022 at 10; R.R. at 134; see also February 2020 

Notice of Return and Claim Return Receipt Verification Card, R.R. at 56a. The 

Bureau has no record of any contact from Appellant after sending the February 2020 

Notice of Return and Claim. See N.T. 4/28/2022 at 10; R.R. at 134a.

On November 5, 2020, the Bureau sent another notice (Open Billing 

Letter), known as an open billing letter,

10 to Appellant at the Property’s address, 

which outlined the real estate tax balance due and payment dates and deadlines for 

satisfaction thereof. See N.T. 4/28/2022 at 11-12; R.R. at 135a; see also Open 

Billing Letter, R.R. at 57a. In addition to the tax balance and payment information, 

the Open Billing Letter also explained that eligible landowners had the option to set 

up a stay of sale contract with the Bureau prior to January 1, 2021, in reference to 

outstanding real estate taxes. See N.T. 4/28/2022 at 11; R.R. at 135a; see also Open 

Billing Letter, R.R. at 57a. Appellant was eligible to enter a stay of sale contract in 

November of 2020, but the Bureau received no response in reference to the Open 

Billing Letter. See N.T. 4/28/2022 at 1; R.R. at 135a.

9 Real estate tax duplicate books are printed at the time the Bureau generates tax bills, and 

are given to the tax collector, who collects taxes on behalf of the Bureau. See N.T. 4/28/2022 at 

8; R.R. at 132a. The parties stipulated that Appellant’s address in the tax duplicate book in 2014 

was 1097 Pitts Road, Mansfield – the address of the Property – and that the address remained the 

same through 2021. See id. No previous correspondence to Appellant at that address was returned 

as undeliverable, and the Bureau has no change of address form for Appellant. See N.T. 4/28/2022 

at 8-9; R.R. at 132a-33a.

10 The RETSL does not require the Bureau to send open billing letters. See N.T. 4/28/2022 

at 11; R.R. at 135a.
7

On April 1, 2021, the Bureau sent Appellant another courtesy notice 

(April 2021 Notice) not required by the RETSL that provided the updated 

outstanding Property real estate tax balance. See N.T. 4/28/2022 at 12; R.R. at 136a; 

see also April 2021 Notice, R.R. at 58a. The April 2021 Notice gave a deadline of 

May 31, 2021, for Appellant to pay the outstanding taxes in full or enter a stay of 

sale contract with the Bureau. See N.T. 4/28/2022 at 12; R.R. at 136a. The Bureau 

received no response to the April 2021 Notice. See id.

On July 14, 2021, the Bureau mailed, via certified mail addressed to 

Appellant as owner, the statutorily required Notice of Public Tax Sale (Notice of 

Sale). See N.T. 4/28/2022 at 14; R.R. at 138; see also Notice of Sale, R.R. at 68a. 

The Notice of Sale listed the Upset Sale for 10:00 a.m., Friday, September 24, 

2021.11 See N.T. 4/28/2022 at 14; R.R. at 138; see also Notice of Sale, R.R. at 68a. 

To avoid publication of the Upset Sale,12 the Notice of Sale gave July 30, 2021, as 

the date for payment in full or entry into a stay of sale contract. See N.T. 4/28/2022 

at 14-15; R.R. at 138a-39a; see also Notice of Sale, R.R. at 68a. The Bureau received 

back a signed return receipt verification card indicating that the Notice of Sale had 

been delivered on July 19, 2021. See N.T. 4/28/2022 at 15; R.R. at 139a; see also

Notice of Sale Return Receipt Verification Card, R.R. at 69a. Appellant’s signed 

name appeared on the signature line of the return receipt verification card. See N.T.

11 The Notice of Sale listed the approximate upset price as $5,887.27. See Notice of Sale, 

R.R. at 68a.

12 On August 26, 2021, the Bureau published the notice of the Upset Sale in the 

Wellsboro/Mansfield Gazette and the Free-Press Courier of Westfield. See N.T. 4/28/2022 at 13-

14; R.R. at 137a-38; see also Affidavits of Publication, R.R. at 60a-67a. The parties stipulated to 

proper publication. See N.T. 4/28/2022 at 14, R.R. at 138a.
8

4/28/2022 at 15; R.R. at 139a; see also Notice of Sale Return Receipt Verification 

Card, R.R. at 69a.

Posting of the Property was completed on June 16, 2021, by Palmetto 

Posting, a third-party posting company. See N.T. 4/28/2022 at 16; R.R. at 140a; see 

also Notice of Public Tax Sale posting, R.R. at 72a-73a; Palmetto Posting Field 

Report (Field Report), R.R. at 71a. Although personal service is required only for 

owner-occupied properties,13 a Palmetto Posting employee also attempted to 

personally serve Appellant with notice of the scheduled Upset Sale on June 16, 17, 

and 18, 2021, but was unsuccessful. See N.T. 4/28/2022 at 16-18; R.R. at 140a-42a; 

see also Field Report, R.R. at 71a.14

On September 8, 2021, the Bureau mailed, by regular mail, a final 

notice to Appellant at the Property’s address (Final Notice) regarding the scheduled 

Upset Sale. See N.T. 4/28/2022 at 21; R.R. at 145a; see also Final Notice, R.R. at

174a. The Final Notice again provided Appellant with a pay-by date to avoid the 

Upset Sale, together with payment instructions. See id. The Final Notice was not 

required by the RETSL. See N.T. 4/28/2022 at 23; R.R. at 147a. The Final Notice 

was not returned as undeliverable, but the Bureau received no response from 

Appellant. See N.T. 4/28/2022 at 21-22; R.R. at 145a-46a.

On September 15, 2021, the Bureau left Appellant a courtesy telephone 

message regarding the Upset Sale and the payment deadline to avoid the Upset Sale. 

13 Bureau records indicate that the Property is not owner-occupied. See N.T. 4/28/2022 at 

18; R.R. at 142a; see also supra n.6.

14 The Trial Court also accepted into evidence at the Amended Objections hearing the 

deposition testimony of Palmetto Posting’s Chief Information Officer, Eugene Johnson, and 

processing agent, Evelyn Laughlin, who collectively confirmed the June 16, 2021 posting of the 

Property and unsuccessful attempts to personally serve notice on Appellant. See Notes of 

Testimony, April 19, 2022, at 8-33; R.R. at 79a-106a.
9

See N.T. 4/28/2022 at 23-24; R.R. at 147a-48a; see also Caller Comments, R.R. at 

75a.

Appellant did not respond to any of the Bureau’s notices. Accordingly, 

the Property was sold at the Upset Sale on September 24, 2021. See N.T. 4/28/2022 

at 24; R.R. at 148a; see also Upset Sale Sold Notice, R.R. at 76a-77a.

Appellant also testified on her own behalf before the Trial Court at the 

hearing on the Amended Objections. See N.T. 4/28/2022 at 28-37; R.R. at 152a61a. Appellant testified that she moved out of the Property and into 661 Pitts Road 

in 2015 as part of an agreement with her sister. See N.T. 4/28/2022 at 30-31; R.R.

at 154a-55a. Appellant further testified to an agreement between herself and her 

mother whereby the mother would pay the Property’s real estate taxes. See N.T. 

4/28/2022 at 32; R.R. at 156a. Appellant asserted that her mother had abided by the 

agreement until the failure to pay the taxes in 2019 occasioned the events leading to 

the Upset Sale. See N.T. 4/28/2022 at 32; R.R. at 156a. Appellant explained that 

she did not receive the notices mailed to the Property, which would have been 

received by her mother and/or sister. See N.T. 4/28/2022 at 32-33; R.R. at 156a57a. Appellant further explained that she has had a strained relationship with her 

mother and sister for years. See N.T. 4/28/2022 at 32-33; R.R. at 156a-57a. 

Appellant testified that the signature on the Notice of Sale was not hers and would 

have instead placed thereon by her mother or sister. See N.T. 4/28/2022 at 33-34; 

R.R. at 157a-58a. She further explained that her mother and sister never advised her 

about the Upset Sale, that she never received a telephone message about the Upset 

Sale, and that she never saw the posting on the Property. See N.T. 4/28/2022 at 35-

36; R.R. at 159a-60a. Appellant conceded, however, that she never informed the 
10

Bureau that she was no longer receiving mail at the Property. See N.T. 4/28/2022 at 

37; R.R. at 161a.

Based on this evidence, the Trial Court found that the Bureau satisfied 

the Section 602 notice requirements of mailing, publication, and posting. See Trial 

Court Opinion at 1-4. The Trial Court observed that the verification from the Notice 

of Sale was returned to the Bureau bearing the signature “Joleen George” in excess 

of 30 days prior to the prior to the September 24, 2021, date of sale. See Trial Court 

Opinion at 2. The Trial Court also noted that the Bureau was excused from the 

additional mailing requirements of Section 602(e)(2), 72 P.S. § 5860.602(e)(2), by 

virtue of the Notice of Sale return receipt having been returned signed, but that the 

Bureau had nonetheless sent multiple other, non-required notification mailings. See 

id. Additionally, the Trial Court noted that the parties had stipulated that the Bureau 

complied with the RETSL’s publication requirement and further that the Bureau 

properly posted the Property as required. See id. Accordingly, the Bureau complied 

with the RETSL’s notification requirements prior to the Upset Sale. See id. at 4.

We agree with the Trial Court that the Bureau fulfilled its notice 

obligations under the RETSL. Section 602 of the RETSL requires the Bureau to 

provide property owners with three forms of notice before an upset sale can take 

place: publication, posting of the property, and mailing of notice. See 72 P.S. § 

5860.602. As discussed supra, Appellant stipulated that the Bureau properly 

published the details of the Upset Sale in two different publications in accordance 

with the RETSL. Additionally, Mr. Zeyn, Mr. Johnson, and Ms. Laughlin all 

testified that the Property was posted on June 14, 2021, well in excess of 10 days 

prior to the Upset Sale, and the Field Report entered into evidence confirmed their

testimony. Further, the Bureau mailed the Notice of Sale on July 14, 2021, well over 
11

30 days prior to the scheduled Upset Sale. The Notice of Sale return receipt 

verification card was returned with Appellant’s signature thereon and indicating that 

the Notice of Sale had been delivered on July 19, 2021, also well over the 30 days 

required by the RETSL. This evidence illustrated that the Bureau complied with the

notice requirements of Section 602 of the RETSL prior to the Upset Sale. For this 

reason, the Trial Court did not err by overruling the Amended Objections to the 

extent they argued that the Bureau had failed to comply with the RETSL’s notice 

requirements prior to the Upset Sale.

To the extent Appellant claimsthat the Trial Court erred by not granting 

equitable relief based on the allegation that her name was forged on the Notice of 

Sale’s return receipt verification card, which forgery Appellant claimed amounts to

fraud, she is not entitled to relief. As this Court has explained, “[w]here the [tax 

claim] bureau has complied with all the notice provisions of Section 602, the fact 

that notice was not actually received will not defeat the sale.” In re Upset Tax Sale 

Held 11/10/97, 784 A.2d 834, 837 (Pa. Cmwlth. 2001) (quoting Kleinberger v. Tax 

Claim Bureau of Lehigh County, 438 A.2d 1045, 1048 (Pa. Cmwlth. 1982)) (wife 

signed certified receipt for husband owner). This Court has further explained that

[w]hen exceptions are filed to a tax sale, the burden of 

proof is on the tax claim bureau to prove compliance with 

the notice requirements of the [RETSL]. This does not,

however, require proof that the property owner actually 

signed the certified mail receipt or actually received the 

notice. Rather, the tax claim bureau must only show that it 

sent all required notices to the property owner or owners, 

not that the owner or owners actually received the notice 

of tax sale.
12

FS Partners v. York Cnty. Tax Claim Bureau, 132 A.3d 577, 581-82 (Pa. Cmwlth. 

2016) (citing 72 P.S. § 5860.602(h)15) (emphasis in original). Thus, this Court has

specifically determined that, 

where the signature on the certified mail receipt appears to 

be the signature of the owner . . . , the tax claim bureau has 

satisfied its certified mail notice obligations and the tax 

sale cannot be set aside for failure to provide certified mail 

or regular mail notice, even if the signature was not the 

actual signature of the owner . . . and the owner did not 

receive the notice and had no knowledge of the tax sale. 

FS Partners, 132 A.3d at 582 (emphasis in original). 

The Trial Court here rejected Appellant’s equity claim as follows:

Appellant asserts that [the Bureau] “. . . knew that 

Appellant’s mother was scheming to achieve sale of 

Appellant’s property at a tax sale.” Appellant also asserts 

that the mail receipt card was not signed by Appellant, but, 

instead, by her mother or sister. While [the Bureau] 

clearly bears the burden of establishing compliance with 

the [RETSL], [the Bureau] is not required to be aware of 

the dynamics of the relationships between property 

owners, such as Appellant, and their relatives. Appellant, 

in asserting a claim such as this, must present evidence to 

support her claim. In this case, Appellant argues that her 

mother and/or sister engaged in a fraud. Appellant alleges 

a forgery by someone with regard to the return receipt. 

Appellant attempts to impute knowledge of a scheme to 

[the Bureau] by reference to a telephone call received by 

[the Bureau] documented in [the Caller Comments, R.R.

at 75a]. The entry, in full, is as follows:

15 Section 602(h) of the RETSL provides: “[n]o sale shall be defeated and no title to 

property sold shall be invalidated because of proof that mail notice as herein required was not 

received by the owner, provided such notice was given as prescribed by this section.” 72 P.S. 

§ 5860.602(h).
13

[Appellant’s mother c]alled to state that 

[Appellant] is no longer going to pay these taxes 

for the [P]roperty. [Appellant] has moved to 

another house at the end of the [P]roperty. 

[Appellant] will not sign over the title to her sister 

Jessica. I told [Appellant’s mother that] she can 

do a tax release and have the taxes sent in her name 

but the title and ownership would still be under 

[Appellant’s name]. [Appellant’s mother] said she 

will wait for it to go to tax sale and bid on it there. 

I told [Appellant’s mother that] she would receive 

a bill of sale if they [sic] were the highest bidder. 

[Appellant’s mother] said she will try to talk to 

[Appellant] about possibly signing it over or 

contact an attorney to see what else she can do.

This communication does not establish a “scheme” to 

defraud Appellant, and certainly does not impute 

knowledge of any such “scheme” to [the Bureau]. Further, 

this communication predates the mailing of the challenged 

certified mail notice by one (1) year. Appellant, herself, 

acknowledged that she provided no notice that she was not 

receiving mail at the [P]roperty, to which the notices were 

sent.

Trial Court Opinion at 2-3.

We agree that Appellant’s equity argument regarding alleged fraud 

based on her mother or sister having possibly forged her signature does not entitle 

Appellant to relief. As discussed supra, the Bureau complied with its notice 

requirements under the RETSL, including mailing the Notice of Sale to Appellant at 

least 30 days prior to the scheduled Upset Sale.16 The return receipt verification card 

from the mailed Notice of Sale came back to the Bureau signed with Appellant’s 

16 We observe that the Bureau in fact mailed the Notice of Sale more than 60 days before 

the scheduled Upset Sale.
14

name. This satisfied the mailing notice requirement, regardless of whether 

Appellant herself actually signed the return receipt, and even if Appellant did not 

actually receive the notice and had no knowledge of the Upset Sale. See FS Partners. 

Accordingly, the Trial Court did not err by overruling the Amended Objections to 

the extent they sought an equitable remedy from the Trial Court based on the 

purportedly forged signature on the Notice of Sale return receipt verification card.

IV. Conclusion

For the above reasons, we find no error in the Trial Court overruling

the Amended Objections.

__________________________________

CHRISTINE FIZZANO CANNON, Judge
IN THE COMMONWEALTH COURT OF PENNSYLVANIA

In Re: Upset Sale, Tax Claim Bureau :

of Tioga County Control No. 00014306 :

(Joleen George) :

: No. 908 C.D. 2022

Appeal of: Joleen R. George :

O R D E R

AND NOW, this 20th day of October, 2023, the July 21, 2022 order of 

the Court of Common Pleas of Tioga County is AFFIRMED.

__________________________________

CHRISTINE FIZZANO CANNON, Judge