HUTCHESON, Circuit Judge.
Into a proceeding brought to condemn land in Harris County, Texas, owned by Amerada Petroleum Corporation, came the State of Texas and Harris County, asserting a tax lien for the years 1922, 1923 and 1926, and claiming $550 of the award. Amerada pleaded and proved that in 1935, at which time Harris County had a population of more than 210,000, it had purchased the land in reliance upon a tax certificate
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