Ark. Code Ann. » Title 26 Chapter 38
Arkansas Code Annotated

Ark. Code Ann. § 26-38-206 (2020)

Effect of the decree of confirmation

✓ Arkansas Code release r76: Acts through about 2020 (2021-2025 sessions missing)
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History. Acts 1993, No. 646, § 5; 2011, No. 1133, § 5.

Amendments. The 2011 amendment rewrote the section.

Case Notes

Applicability.

Debtor who claimed an equitable interest in the property based on an alleged oral rent-to purchase agreement with the owner could challenge the tax sale and transfer of property to the subsequent purchaser because the state did not file an action in Chancery Court under § 26-38-206, to bar any subsequent claims. Further, § 26-37-203 gave the debtor two years to contest the validity of the conveyance. In re Paro, 362 B.R. 419 (Bankr. E.D. Ark. 2007).

Notes of Decisions
Cited in 2 cases (1 in the last 5 years), 2007–2026 · leading case: Lang Props., LLC v. Michael Grober, 2026 Ark. App. 281.
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Lang Props., LLC v. Michael Grober, 2026 Ark. App. 281. · cites it 2× “From those core assumptions, Lang more specifically and understandably argues that upon confirmation of the July 2023 tax sale, the Commissioner’s deed should “vest the complete and indefeasible title to the real property” in Lang and his grantees “in fee simple, free and clear…”
In re Paro, 362 B.R. 419 (Bankr. E.D. Ark. 2007). “§ 26-38-206(a), The decree of the chancery court confirming the forfeiture and conveyance to the state of real property shall operate, except only as expressly provided in this section, as a complete bar, both at law and in equity, against any and all persons, firms,…”
Ark. Code Ann. § 26-38-206(a): 1 case
In re Paro, 362 B.R. 419 (Bankr. E.D. Ark. 2007). “§ 26-38-206(a), The decree of the chancery court confirming the forfeiture and conveyance to the state of real property shall operate, except only as expressly provided in this section, as a complete bar, both at law and in equity, against any and all persons, firms,…”
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