OPINION
TOUSSAINT, Chief Judge.
The Internal Revenue Service, unaware that the cancellation of a contract for deed on the property had extinguished the interest of the defaulting taxpayer, the vendee, held an auction of the taxpayer's interest. Appellant purchased the interest and attempted to obtain a warranty deed from respondents, successors in interest to the vendor, by paying them the amount due on the contract for deed. When respondents refused, she...
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