Ohio Revised Code

Ohio Rev. Code § 5721.181 (2026)

Substance of forms

✓ current as of May 2026
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The forms of caption, notice of foreclosure, and notice to property owners, lienholders, and other interested persons to be utilized in a foreclosure proceeding instituted pursuant to division (B) of section 5721.18 of the Revised Code shall be in substance as follows:

(A) Form of caption:

"In the __________ court of __________, Ohio,

in the matter of the foreclosure of liens

for delinquent land taxes by action in rem.

County treasurer of __________ county, Ohio,

Plaintiff

vs.

Parcels of land encumbered with delinquent tax liens,

defendants"

(B) Form of notice of foreclosure:

"__________ court __________ county, Ohio

Notice of foreclosure of liens for delinquent land taxes, by action in rem by county treasurer of __________ county, Ohio

Public notice is hereby given that on the __________ day of __________, ____, the county treasurer of __________ county, Ohio, filed a complaint in the __________ court of __________, Ohio, at __________ (stating the city), for the foreclosure of liens for delinquent taxes, assessments, charges, penalties, and interest against certain real property situated in such county, as described in that complaint.

The object of the action is to obtain from the court a judgment foreclosing the tax liens against such real estate and ordering the sale of such real estate for the satisfaction of the tax liens on it.

Such action is brought against the real property only and no personal judgment shall be entered in it. However, if pursuant to the action the property is sold for an amount that is less than the amount of the delinquent taxes, assessments, charges, penalties, and interest against it, the court, in a separate order, may enter a deficiency judgment against the owner of record of a parcel for the amount of the difference; if that owner of record is a corporation, the court may enter the deficiency judgment against the stockholder holding a majority of the corporation's stock.

The permanent parcel number of each parcel included in such action; the full street address of the parcel, if available; a description of the parcel as set forth in the associated delinquent land tax certificate or master list of delinquent tracts; a statement of the amount of the taxes, assessments, charges, penalties, and interest due and unpaid on the parcel; the name and address of the last known owner of the parcel as they appear on the general tax list; and the names and addresses of each lienholder and other person with an interest in the parcel identified in a statutorily required title search relating to the parcel; all as more fully set forth in the complaint, are as follows:

(Here set forth the respective permanent parcel numbers, street addresses, descriptions, names and addresses of owners, lienholders, and other interested persons, and statements of amounts due as taxes, assessments, charges, penalties, and interest, together with the respective serial numbers assigned to each parcel if the complaint covers more than one parcel. If parcels are identified in this notice by permanent parcel number only, instead of also with a complete legal description, as authorized by division (B)(1) of section 5721.18 of the Revised Code, here also set forth where the complete legal description of the parcel may be obtained.)

Any person owning or claiming any right, title, or interest in, or lien upon, any parcel of real property above listed may file an answer in such action setting forth the nature and amount of interest owned or claimed and any defense or objection to the foreclosure. Such answer shall be filed in the office of the undersigned clerk of the court, and a copy of the answer shall be served on the prosecuting attorney, on or before the __________ day of __________, ____ (twenty-eight days after the date of final publication of this notice).

If no answer is filed with respect to a parcel listed in the complaint, on or before the date specified as the last day for filing an answer, a judgment of foreclosure will be taken by default as to that parcel. Any parcel as to which a foreclosure is taken by default shall be sold for the satisfaction of the taxes, assessments, charges, penalties, and interest, and the costs incurred in the foreclosure proceeding, which are due and unpaid.

At any time prior to the filing of an entry of confirmation of sale, any owner or lienholder of, or other person with an interest in, a parcel listed in the complaint may redeem the parcel by tendering to the treasurer the amount of the taxes, assessments, charges, penalties, and interest due and unpaid on the parcel, together with all costs incurred in the proceeding instituted against the parcel under section 5721.18 of the Revised Code. Upon the filing of any entry of confirmation of sale, there shall be no further equity of redemption. After the filing of any such entry, any person claiming any right, title, or interest in, or lien upon, any parcel shall be forever barred and foreclosed of any such right, title, or interest in, lien upon, and any equity of redemption in, such parcel.

_________________________

Clerk of the Court

___________________ Court

___________________, Ohio"

(C) Form of notice to owner, lienholders, and other persons with an interest in a parcel:

"To the person to whom this notice is addressed:

You are the last known owner, according to the general tax list, or a lienholder of, or a person with another interest in, the following described parcel:

(Description as shown in complaint)

Such parcel has been included in an action instituted by the county treasurer, being case No. ________ filed in the __________ court, ___________, Ohio, on __________, ____, seeking the foreclosure and sale of such parcel for the nonpayment of delinquent taxes, assessments, charges, penalties, and interest (specify which) in the amount of $__________

Any person owning or claiming any right, title, or interest in, or lien upon, such parcel may file an answer in the action setting forth the nature and amount of the person's interest and any defense or objection to the foreclosure. Any such answer shall be filed in the office of the undersigned clerk of the court, and a copy of the answer shall be delivered to the prosecuting attorney, on or before __________, ____ (twenty-eight days after the final publication of the associated notice of foreclosure in accordance with law).

If no answer is filed, a judgment of foreclosure will be taken by default and such parcel shall be ordered sold for the satisfaction of the tax lien on it.

If, pursuant to the action, the property is sold for an amount that is less than the amount of the delinquent taxes, assessments, charges, penalties, and interest against it, the court, in a separate order, may enter a deficiency judgment against the owner of record of a parcel for the amount of the difference. If that owner of record is a corporation, the court may enter the deficiency judgment against the stockholder holding a majority of that corporation's stock.

At any time prior to the filing of any entry of confirmation of sale, any owner or lienholder of, or other person with an interest in, a parcel may redeem the parcel by tendering to the treasurer the full amount of the taxes, assessments, charges, penalties, and interest due and unpaid on the parcel, together with all costs incurred in the proceeding instituted against the parcel under section 5721.18 of the Revised Code. Upon the filing of any entry confirming the sale of the parcel, there shall be no further equity of redemption. After the filing of any such entry, any person claiming any right, title, or interest in, or lien upon, the parcel shall be forever barred and foreclosed of any such right, title, or interest in, lien upon, and any equity of redemption in, the parcel.

_________________________

Clerk of the Court

___________________ Court

___________________, Ohio"

Notes of Decisions
Cited in 9 cases (4 in the last 5 years), 1980–2025 · leading case: In re Foreclosure of Liens for Delinquent Land Taxes v. Parcels of Land Encumbered with Delinquent Tax Liens (Slip Opinion), 2014 Ohio 3656 (Ohio 2014).
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In re Foreclosure of Liens for Delinquent Land Taxes v. Parcels of Land Encumbered with Delinquent Tax Liens (Slip Opinion), 2014 Ohio 3656 (Ohio 2014). · cites it 6× “Vanderbilt contends that when read in conjunction with other provisions on tax foreclosure proceedings — namely, R.C. 5721.181, which provides the form of notice required — the phrase “any person entitled to redeem the land” under R.”
United States v. Dansby, 509 F. Supp. 188 (N.D. Ohio 1981). · cites it 6× “Such actión shall be instituted by filing in the office of the clerk of a court of competent jurisdiction, a complaint bearing a caption substantially in the form set forth in section 5721.181 [5721.18.1] of the Revised Code.”
In re Foreclosure of Liens for Delinquent Taxes, 405 N.E.2d 1030 (Ohio 1980). · cites it 2× “Such action shall be instituted by filing in the office of the clerk of a court of competent jurisdiction, a complaint bearing a caption substantially in the form set forth in section 5721.181 of the Revised Code.***A complaint shall contain***the name and address of the last…”
In re Foreclosure of Liens & Delinquent Taxes by Action in Rem v. Jaber, 2023 Ohio 4247 (Ohio Ct. App. 2023). · cites it 3× “*** Within thirty days after the filing of a complaint and before the final date of publication of the notice of foreclosure, the clerk of the court also shall cause a copy of a notice substantially in the form of the notice set forth in division (C) of section 5721.181 of the…”
Nix v. Richter, 2017 Ohio 8431 (Ohio Ct. App. 2017). “The complaint does not make any reference to an in rem proceeding, or comply with the statutory form for filing an action in rem, as detailed in R.C. 5721.181. In short, the record before this court makes clear that this action was pursued based on in personam jurisdiction.”
Bolon v. Bowers, 2022 Ohio 2648 (Ohio Ct. App. 2022). · cites it 2× “*** Within thirty days after the filing of a complaint and before the final date of publication of the notice of foreclosure, the clerk of the court also shall cause a copy of a notice substantially in the form of the notice set forth in division (C) of section 5721.181 of the…”
McManus v. Anderson, 2025 Ohio 2542 (Ohio Ct. App. 2025). “18(B) and R.C. 5721.181, which R.C. 5721.18(B) incorporates.”
Lakeside REO Ventures, L.L.C. v. Vandeleur Investors, L.L.C., 2015 Ohio 4254 (Ohio Ct. App. 2015). “25, "any person entitled to redeem the land" includes "any owner or lienholder of, or other person with an interest in" the subject property as set forth in R.C. 5721.181. In re Foreclosure of Liens for Delinquent Land Taxes v.”
Lorain Cty. Treasurer v. Bray, 2025 Ohio 5688 (Ohio Ct. App. 2025). · cites it 2× “Under Section 5721.181, “no personal judgment shall be entered” in a tax foreclosure action; however, a deficiency judgment may be entered against the owner of the property if it is sold for less than the amount of the delinquent taxes and other charges.”
Ohio Rev. Code § 5721.181(B): 1 case
In re Foreclosure of Liens for Delinquent Land Taxes v. Parcels of Land Encumbered with Delinquent Tax Liens (Slip Opinion), 2014 Ohio 3656 (Ohio 2014). “Vanderbilt contends that when read in conjunction with other provisions on tax foreclosure proceedings — namely, R.C. 5721.181, which provides the form of notice required — the phrase “any person entitled to redeem the land” under R.”
Ohio Rev. Code § 5721.181(C): 1 case
In re Foreclosure of Liens & Delinquent Taxes by Action in Rem v. Jaber, 2023 Ohio 4247 (Ohio Ct. App. 2023). “*** Within thirty days after the filing of a complaint and before the final date of publication of the notice of foreclosure, the clerk of the court also shall cause a copy of a notice substantially in the form of the notice set forth in division (C) of section 5721.181 of the…”
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