original tax sale. See Anderson, 44 F.3d at 797. However, there had not been a successful sale of the property in that case; the Andersens filed suit against the IRS prior to the second attempted sale. See id. Therefore, it was unnecessary for that court to determine whether any sale was void or voidable. Consequently, these cases do not support the Johnstons’ position. The Johnstons also urge this Court to hold that, for the purposes of characterizing an action in violation of section 6335, the terms voidable and void are both intended to mean only void. Appellants cite no law to support their argument. On the contrary, it is clear that courts have considered the difference between void sales and voidable sales when ruling on section 6335 violations. See Koby, 47 Fed. Cl. at 104-05 (<HOLDING>); DRWSEA, 132 S.W.3d at 469 (asserting that “a
holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law holding that although irs failed to comply with procedures of section 6335 tax sale was valid due to ratification by taxpayer holding that a contract made in violation of section 432070 is void rather than voidable holding that failure of irs to provide statutory notice of sale caused sale to be voidable ab initio holding that fraudulent inducement renders a contract void or voidable