Conn. Gen. Stat. » Title 12 — TAXATION · Chapter 204 — Local Levy and Collection of Taxes
Connecticut General Statutes

Conn. Gen. Stat. § 12-159 (2025)

Collector's deed as evidence. Irregularities

✓ laws through the 2024 session: the source has not yet published 2025 Public Acts (checked Sept. 2026)
Find cases: SyfertCases citing this section CT-CGAcga.ct.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
Any deed, or the certified copy of the record of any deed, purporting to be executed by a tax collector and similar, or in substance similar, to the above, shall be prima facie evidence of a valid title in the grantee to the premises therein purported to be conveyed, encumbered only by the lien of taxes to the municipality which were not yet due and payable on the date notice of levy was first made, easements and similar interests appurtenant to other properties not thereby conveyed, and other interests described therein and of the existence and regularity of all votes and acts necessary to the validity of the tax therein referred to, as the same was assessed, and of the levy and sale therefor, and no tax collector shall be required to make return upon his warrant of his doings thereunder, except that the purchaser may, within ninety days of the recording of the collector's deed, request in writing from the tax collector, an affidavit which complies with the provisions of section 12-167a. The tax collector shall provide such affidavit within thirty days of receipt of such request. The town clerk shall record such affidavit in the land records of such town and shall index the affidavit under the name of the purchaser as grantee. No act done or omitted relative to the assessment or collection of a tax, including everything connected therewith, after the vote of the community laying the same, up to and including the final collection thereof or sale of property therefor, shall in any way affect or impair the validity of such tax as assessed, collected or sought to be collected or the validity of such sale, unless the person seeking to enjoin or contesting the validity of such sale shows that the collector neglected to provide notice pursuant to section 12-157, to such person or to the predecessors of such person in title, and who had a right to notice of such sale, and that the person or they in fact did not know of such sale within six months after it was made, and provided such property was by law liable to be sold to satisfy such tax. The fact that the collector may have charged or received illegal fees upon such sale shall not impair the sale's validity. If the person contesting such fees shows that illegal fees were charged by the collector, the municipality shall refund such illegal fees together with legal interest from the date of their payment in accordance with section 12-129.

(1949 Rev., S. 1840; P.A. 95-228, S. 5, 15; P.A. 99-283, S. 5, 10; P.A. 13-276, S. 32.)

History: P.A. 95-228 added provisions re encumbrances on a title, affidavits on the collector's actions and refunds of illegal fees charged by a collector and made technical changes, effective July 6, 1995, and applicable to tax sale notices posted, filed or published on and after said date; P.A. 99-283 replaced “one year” with “six months” and made changes for gender neutrality, effective June 29, 1999; P.A. 13-276 added provision requiring person seeking to enjoin a sale to show neglect of collector to provide notice.

Does not validate sale, where levy made for one tax and land sold for others. 87 C. 146. Cited. 126 C. 212.

Cited. 46 CA 721. Section reflects legislative support for principle that easements appurtenant run with the land and are not extinguished when title is conveyed pursuant to a tax lien foreclosure. 63 CA 164. Section provides plaintiff standing to contest validity of tax sale by showing that notice was not properly provided to his predecessor in title in accordance with Sec. 12-157(a). 138 CA 1.

(Return to Chapter
Table of Contents)		 (Return to
List of Chapters)		 (Return to
List of Titles)

Notes of Decisions
Cited in 9 cases (3 in the last 5 years), 1997–2026 · leading case: Cornelius v. Rosario, 51 A.3d 1144 (Conn. App. Ct. 2012).
Sort: Relevance Newest Treatment
Cornelius v. Rosario, 51 A.3d 1144 (Conn. App. Ct. 2012). · cites it 6× “He argues that § 12-159 authorizes a person whose predecessor in title was entitled to notice of the tax sale under § 12-157 to contest the validity of the notice given to his or her predecessor in title.”
Faught v. Edgewood Corners, Inc., 772 A.2d 1142 (Conn. App. Ct. 2001). · cites it 5× “.” On the basis of this principle, the defendant reasons that title conveyed pursuant to a tax lien foreclosure is obtained unencumbered by a prescriptive easement.”
Berger v. Fitzgerald, 739 A.2d 287 (Conn. App. Ct. 1999). · cites it 9× “1' General Statutes § 12-159, as in effect in 1991, was not amended until Public Acts 1995, No.”
Jacobson v. A1Z7, LLC (In re Jacobson), 523 B.R. 13 (Bankr. D. Conn. 2014). · cites it 2× “a public sale was held following the transfer of title, the court used the amount realized by the tax collector from the auction as the amount recoverable by the taxpayer as a fraudulent transfer (less taxes owed), rather than what the taxpayer claimed to be the substantially…”
Assocs. Fin. Servs. of Am., Inc. v. Sorensen, 700 A.2d 107 (Conn. App. Ct. 1997). “to 1993) § 12-159 provides in relevant part: “Any deed, or the certified copy of the record of any deed, purporting to be executed by a tax collector .”
McCullough v. Rocky Hill, No. AC47717 (Conn. App. Ct. May 19, 2026). · cites it 29× “” The town argued that “[t]he plaintiff does not dispute that the taxes on his property are seriously delinquent, that the sale notices and other procedures have been followed flawlessly, and that he 3 General Statutes § 12-159 provides in relevant part: “No act done or omitted…”
Peterson v. Torrington, 229 A.3d 119 (Conn. App. Ct. 2020). · cites it 7× “’’ 7 General Statutes § 12-159 provides in relevant part: ‘‘Any deed, or the certified copy of the record of any deed, purporting to be executed by a tax collector and similar, or in substance similar, to the above, shall be prima facie evidence of a valid title in the grantee…”
Speer v. New London, 537 F. Supp. 3d 212 (D. Conn. 2021). · cites it 3× “ty laying the same, up to and including the final collection thereof or sale of property therefor, shall in any way affect or impair the validity of such tax as assessed, collected or sought to be collected or the validity of such sale, unless the person seeking to enjoin or…”
Homeowners Fin. Co. v. Lamont, No. 3:20-cv-01282 (D. Conn. Sept. 20, 2021). “[and then] pursue the unpaid taxes,” thus rejecting Homeowners’ argument that the tax sale was invalid because Crovo had already paid Torrington the taxes due on the property; and ultimately holding that “[i]n this case, §12-157 permits the [Harwinton] Property to be sold,…”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.