Opinion Number

Dear Mr. Smith:

Reference is made to your request for an opinion of this office regarding the situation in which the buyer of property at an ad valorem tax sale receives only a fractional interest (an undivided interest) in the tax debtor's property, such as a 1/100,000,000 interest. When this occurs, the tax debtor continues as owner of remaining undivided interest of property. Since you have always believed that an individual who fails to pay his taxes would lose his entire interest therein, you have asked for our opinion as to whether these sales of fractional portions (undivided interests)…