CCD-SAT, Inc. v. Pratt

Summary

The District of Columbia Court of Appeals considers whether a tax deed conveying property to Clarence T. Pratt was valid when the District could not show that it provided the statutorily required notice to CCD-SAT, a Maryland corporation whose charter had been forfeited. The court held that CCD-SAT’s forfeited status did not excuse strict compliance with the notice requirement because its sole director became trustee of the corporation’s assets and was also its registered agent. The court reversed and remanded for an order setting aside the tax deed and for further proceedings.

Holdings

1. A corporation's forfeited or defunct status does not, on the particular facts of this case, excuse the District from strictly complying with the statutory requirement to send written notice to the record owner before privately selling tax-delinquent property.
2. Because the District could not show that it sent the statutorily required thirty-day notice, the tax sale was invalid and the tax deed must be set aside.

Questions Presented

1. Whether CCD-SAT's forfeited corporate status excused the District from complying with the statutory requirement to provide written notice before privately selling the tax-delinquent property.
2. Whether the absence of evidence that the District sent the required notice rendered the tax sale and resulting tax deed invalid under the tax-sale statute and constitutional due-process requirements.

Disposition

reversed_and_remanded