Sec. 33.54. LIMITATION ON ACTIONS RELATING TO PROPERTY SOLD FOR TAXES. (a) Except as provided by Subsection (b), an action relating to the title to property may not be maintained against the purchaser of the property at a tax sale unless the action is commenced:
(1) before the first anniversary of the date that the deed executed to the purchaser at the tax sale is filed of record; or
(2) before the second anniversary of the date that the deed executed to the purchaser is filed of record, if on the date that the suit to collect the delinquent tax was filed the property was:
(A) the residence homestead of the owner; or
(B) land appraised or eligible to be appraised under Subchapter C or D, Chapter 23.
(b) If a person other than the purchaser at the tax sale or the person's successor in interest pays taxes on the property during the applicable limitations period and until the commencement of an action challenging the validity of the tax sale and that person was not served citation in the suit to foreclose the tax lien, that limitations period does not apply to that person.
(c) When actions are barred by this section, the purchaser at the tax sale or the purchaser's successor in interest has full title to the property, precluding all other claims.
Acts 1979, 66th Leg., p. 2296, ch. 841, Sec. 1, eff. Jan. 1, 1982. Amended by Acts 1997, 75th Leg., ch. 1136, Sec. 1, eff. Sept. 1, 1997; Acts 1997, 75th Leg., ch. 1192, Sec. 1, eff. Sept. 1, 1997.
Notes of Decisions
Cited in
48
cases (
15 in the last 5 years), 1983–2026 · leading case:
Sani v. Powell, 153 S.W.3d 736 (Tex. App. 2005).
Sani v. Powell, 153 S.W.3d 736 (Tex. App. 2005).
· cites it 20× “See Tex. Tax Code Ann. § 33.54 (Vernon 2001).”
Jordan v. Bustamante, 158 S.W.3d 29 (Tex. App. 2005).
· cites it 5× “See Tex. Tax Code Ann. § 33.54 (Vernon 2001).”
Roberts v. T.P. Three Enter., Inc., 321 S.W.3d 674 (Tex. App. 2010).
· cites it 5× “In general, appellants complain that the trial court erred in granting summary judgment in favor of appellee because (1) the limitations periods of Texas Tax Code section 33.54 did not bar them from bringing suit, (2) appellants had no notice of the tax suit, and (3) the final…”
Session v. Woods, 206 S.W.3d 772 (Tex. App. 2006).
· cites it 3× “Tex. Tax Code Ann. § 33.54 . There is no claim or evidence which would trigger application of subsections (a)(2) or (b) on Session’s behalf.”
Cedillo v. Gaitan, 981 S.W.2d 388 (Tex. App. 1998).
· cites it 6× “Tex. Tax Code Ann. § 33.54 (Vernon 1987) (amended 1997) (current version at Tex.”
Williams v. Khalaf, 802 S.W.2d 651 (Tex. 1990).
“021(c), (d) (Vernon 1984) (a type of two year limitations period for damages claim incident to trespass to try title action, with some limitations of defendant's right to counterclaim for valuable improvements made during good faith adverse possession of the property in…”
Ocwen Loan Servicing LLC v. Gonzalez Fin. Holdings, Inc., 77 F. Supp. 3d 584 (S.D. Tex. 2015).
· cites it 2× “” Tex. Tax Code § 33.54(a)(1). 5 This one-year limitations period may be tolled for “a person other than the purchaser at the tax sale or the person’s successor in interest” who “was not served citation in the suit to foreclose the tax lien” if the person “pays taxes on the…”
— Tex. Tax Code § 33.54(a) — 9 cases
— Tex. Tax Code § 33.54(a)(1) — 7 cases
Ocwen Loan Servicing LLC v. Gonzalez Fin. Holdings, Inc., 77 F. Supp. 3d 584 (S.D. Tex. 2015).
“” Tex. Tax Code § 33.54(a)(1). 5 This one-year limitations period may be tolled for “a person other than the purchaser at the tax sale or the person’s successor in interest” who “was not served citation in the suit to foreclose the tax lien” if the person “pays taxes on the…”
Obra J. Moore, III, Indio Minerals LLC, Gunner Oil Series LLC, & Madaket Energy LLC, Cobalt Nat. Resources LLC, & Magnolia Nat. Resources LLC v. 1789 Minerals Fund I, LP, Rockcliff Energy Operating LLC, Caddo Minerals Inc., & Regina Roberts (2026).
— Tex. Tax Code § 33.54(a)(2) — 1 case
Ocwen Loan Servicing LLC v. Gonzalez Fin. Holdings, Inc., 77 F. Supp. 3d 584 (S.D. Tex. 2015).
“” Tex. Tax Code § 33.54(a)(1). 5 This one-year limitations period may be tolled for “a person other than the purchaser at the tax sale or the person’s successor in interest” who “was not served citation in the suit to foreclose the tax lien” if the person “pays taxes on the…”
— Tex. Tax Code § 33.54(b) — 5 cases
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