G.J. Gaynor v. Delaware County TCB & CJD Group, LLC, 580 C.D. 2023

Gloria J. Gaynor appealed a Delaware County Common Pleas Court order denying her petition to set aside a tax sale of her property at 335 Wayne Avenue, Lansdowne, PA.
The property was sold at a tax sale for $14,419.00 (the full upset price) due to unpaid 2020 real estate taxes.
Gaynor challenged the sale, initially claiming improper notice and that she was not offered an installment plan as required by statute, though she later conceded the notice claim.
She argued the sale price was grossly inadequate compared to an appraisal value of $285,000, but did not allege or prove any irregularities in the sale process itself.
The trial court found no basis to set aside the sale, as there were no irregularities contributing to the alleged inadequacy of price.
The Commonwealth Court affirmed the trial court’s denial of her petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the tax sale price grossly inadequate to set aside the sale?	Price was grossly inadequate; property worth about 20x more than upset price.	No sale irregularities alleged or proven; sale met legal requirements.	Price inadequacy alone is insufficient without irregularity; affirmed.

In re Adams Cnty. Tax Claim Bureau, 200 A.3d 622 (Pa. Cmwlth. 2018) (upset tax sales recover upset price for tax claims; sale must meet at least this minimum)
In re Upset Sale, Tax Claim Bureau of Tioga Cnty., Control No. 012488, 305 A.3d 1118 (Pa. Cmwlth. 2023) (mere inadequacy of tax sale price is not sufficient to set aside sale absent irregularities)
Allegheny Cnty. v. Golf Resort, Inc., 974 A.2d 1242 (Pa. Cmwlth. 2009) (irregularities plus grossly inadequate price can justify setting aside sale; not present here)