Lowe v. City of Atlanta

Cook, Justice.

In the petition as originally brought it was contended that the Federal tax liens under which the property was sold on July 1, 1963, were superior to the liens for taxes claimed by the City of Atlanta. The city does not contest this position, and the question of lien priorities is not the •controlling issue in the case.

The Federal law under which the property was sold provides for the sale of seized real property and for the issuance of a '“certificate of sale” to the purchaser at the tax sale. 26 U.S. C.A. §§ 6335, 6338. Should the taxpayer fail to redeem the real property sold…