(Tex.1995). Validity of Tax Sale In their second point of error, the John-stons assert that the trial court erred by denying their summary judgment motion claiming that the quitclaim deed issued by the IRS was void because the IRS did not strictly comply with the applicable statutes governing seizure and sale of the property. The Johnstons contend that, according to the Internal Revenue Code, the IRS failed to sell the property in a timely fashion and in the correct county after it was seized or to return the property to them after the postponement of the first sealed bid sale. See 26 U.S.C.S. § 6335(d), (e) (2003) (establishing procedures for manner of sale of seized property). As a result of the IRS’s failure to comply with the statute, the Johnstons argue that the sale of the p 0) (<HOLDING>); DRWSEA, Inc. v. Trinity Meadows Prop., Inc.,
holding that failure of irs to provide statutory notice of sale caused sale to be voidable ab initio holding that a contract made in violation of section 432070 is void rather than voidable holding that although irs failed to comply with procedures of section 6335 tax sale was valid due to ratification by taxpayer holding that fraudulent inducement renders a contract void or voidable 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