In Hart v. Bulldawg and City of Philadelphia Department of Revenue, an unreported 2–1 opinion filed on Feb. 14, (107 C. D. 2016), the Commonwealth Court vacated a sale under the Municipal Claims and Tax Lien Act (MCTLA). What makes this opinion noteworthy is that a tax sale was successfully challenged because of an alleged grossly inadequate sale price. As is evident from the opinion, setting aside a tax sale for a grossly inadequate sale price in Pennsylvania is not a common occurrence.
On Feb. 18, 2015, the only bidder, Bulldawg, LLC purchased the property for $1,100. On March 10, Hart filed a pro se petition to set aside the sheriff sale alleging only that he did not receive notice of the proceedings. On April 13, two weeks after the sheriff deed was delivered, Hart filed an amended petition, abandoning his due process claim, alleging instead that the failure to set aside the sheriff sale would be a gross injustice.
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