ILCS » Chapter 35 · Act 200
Illinois Compiled Statutes

35 ILCS 200/22-50 (2026)

Denial of deed

✓ current as of May 2026
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(35 ILCS 200/22-50)
    Sec. 22-50. Denial of deed. If the court refuses to enter an order directing the county clerk to execute and deliver the tax deed, because of the failure of the purchaser to fulfill any of the above provisions, and if the purchaser, or his or her assignee has made a bona fide attempt to comply with the statutory requirements for the issuance of the tax deed, then upon application of the owner of the certificate of purchase the court shall declare the sale to be a sale in error.
(Source: P.A. 92-224, eff. 1-1-02.)

    
Notes of Decisions
Cited in 19 cases (4 in the last 5 years), 2005–2024 · leading case: In Re Application of Cnty. Treasurer, 824 N.E.2d 614 (Ill. 2005).
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In Re Application of Cnty. Treasurer, 824 N.E.2d 614 (Ill. 2005). “sale and of the property owner's redemption rights (35 ILCS 200/22-5 (West 2000)); notice of the expiration of the period of redemption (35 ILCS 200/22-10 (West 2000)); notice by publication (35 ILCS 200/22-20 (West 2000)); a petition by the purchaser for issuance of a tax deed…”
In re Application of the Cnty. Collector for Judgment & Order of Sale Against Lands & Lots Returned Delinquent for Nonpayment of Gen. Taxes for the Year 2009, 2015 IL App (4th) 140810 (Ill. App. Ct. 2015). · cites it 6× “Gupta, appeals the trial court’s denial of his petition for issuance of a tax deed and finding of a sale in error pursuant to section 22-50 of Property Tax Code (Code) (35 ILCS 200/22-50 (West 2012)). He argues the court erred in finding he failed to comply with the relevant…”
In re Woodruff, 600 B.R. 616 (Bankr. N.D. Ill. 2019). “35 ILCS 200/22-50 ; see also, e.g. , In re Application of Cty.”
In re Application of the Cnty. Collector, 2014 IL App (2d) 140223 (Ill. App. Ct. 2015). “¶8 On September 23, 2013, the petitioner filed a petition for an order declaring a sale in error pursuant to section 22-50 of the Property Tax Code (35 ILCS 200/22-50 (West 2012)). On October 23, 2013, the trial court conducted a hearing on the petition.”
In re Application of the Cnty. Collector v. Eldridge, 2015 IL App (4th) 140810 (Ill. App. Ct. 2015). · cites it 5× “Gupta, appeals the trial court's denial of his petition for issu- ance of a tax deed and finding of a sale in error pursuant to section 22-50 of Property Tax Code (Code) (35 ILCS 200/22-50 (West 2012)). He argues the court erred in finding he failed to com- ply with the relevant…”
In re Application of the Kane Cnty. Collector, 2014 IL App (2d) 140265 (Ill. App. Ct. 2014). · cites it 2× “Request for Sale in Error Pursuant to Section 22-50 ¶ 21 Petitioner next argues that the trial court erred in failing to declare a sale in error pursuant to section 22-50 (35 ILCS 200/22-50 (West 2010)). It argues that its section 22-5 notices were deficient because they listed…”
In re Application of the Kane Cnty. Collector, 2014 IL App (2d) 140265 (Ill. App. Ct. 2014). · cites it 2× “Alternatively, petitioner asked the court to declare a sale in error pursuant to section 22-50 of the Code (35 ILCS 200/22-50 (West 2010)) on the basis 2014 IL App (2d) 140265 that, despite bona fide efforts to comply, petitioner’s notices to the property owner did not…”
In re Application of the Cnty. Collector, 2017 IL App (2d) 160483 (Ill. App. Ct. 2017). “¶6 On September 23, 2013, Wolfe filed a petition for an order declaring a sale in error pursuant to section 22-50 of the Code (35 ILCS 200/22-50 (West 2012)), based on a typographical error that improperly extended the redemption date by three days.”
In re Application of the Cnty. Treasurer & ex officio Cnty. Collector, 2014 IL App (2d) 130995 (Ill. App. Ct. 2015). “Had that occurred, the petitioner would have been entitled to petition for a refund pursuant to section 22-50 of the Property Tax Code (35 ILCS 200/22-50 (West 1994)) if she could establish that she made a bona fide attempt to comply with the statutory requirements for the…”
In re Application of the Cnty. Collector, 2017 IL App (3d) 150809 (Ill. App. Ct. 2017). “35 ILCS 200/22-50 (West 2014). A sale in error ruling entitles the buyer to receive a refund of all the amounts he has paid.”
In re Application of the Cnty. Collector, 2017 IL App (2d) 160483 (Ill. App. Ct. 2017). “On August 20, 2013, the trial court denied the petition, finding that Wolfe could have, through due diligence, discovered the discrepancy and the reasons for it prior to purchasing the taxes.”
Newline Holdings, LLC v. ND Fin., LLC, 2024 IL App (1st) 230136-U (Ill. App. Ct. 2024). · cites it 2× “The Treasurer initially argued that a petitioner’s application for tax deed must be denied prior to requesting the sale in error under section 22-50 of the Property Tax Code (35 ILCS 200/22-50 (West 2022)). The Treasurer further maintained that ND Financial did not present…”
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