Vermont Statutes Annotated

Vt. Stat. Ann. tit. 32, § 5252 (2026)

✓ current as of May 2026
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Subchapter 009 : DELINQUENT TAXES

(Cite as: 32 V.S.A. § 5252)
Notes of Decisions
Cited in 13 cases (4 in the last 5 years), 1970–2025 · leading case: Johnathan J. Billewicz v. Town of Fair Haven, 2021 VT 20 (Vt. 2021).
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Johnathan J. Billewicz v. Town of Fair Haven, 2021 VT 20 (Vt. 2021). · cites it 2× “Just so here: plaintiffs’ suit seeking to void the tax collector’s deeds on grounds that he failed to record a report of his doings as required by § 5255 is barred under § 5294(4)’s one-year limitation period because they commenced their action more than a year after the levy.”
Hogaboom v. Jenkins v. Town of Milton, 2014 VT 11 (Vt. 2014). · cites it 2× “The trial court denied the summary judgment motions, concluding that although the Town complied with the statutory notice requirements of 32 V.S.A. § 5252, the Town failed to provide sufficient notice to taxpayer to satisfy the constitutional requirement of due process.”
Ran-Mar, Inc. v. Town of Berlin, 2006 VT 117 (Vt. 2006). “The Town notes, however, that notice of the sale must also be given to each “lien holder of record,” 32 V.S.A. § 5252(4), and that this must mean that the lien holders have a sufficient interest to also give them the right to redeem.”
Turner v. Spera, 433 A.2d 307 (Vt. 1981). · cites it 3× “§ 5294 (4), and that the tax collector’s failure to publish notice of the tax sale by three successive advertisements in the local newspaper, as required by 32 V.S.A. § 5252 (2), was an omission of insufficient magnitude to negate jurisdiction to effectuate a tax sale.”
Chester Motors, Inc. v. Koledo, 503 A.2d 551 (Vt. 1985). · cites it 3× “The appellant contends that this reference to the inapplicable warranty deed makes the tax sale void, because the notice of sale contains an ambiguity and therefore doesn’t comply with 32 V.S.A. §§ 5252, 5253. However, 32 V.S.”
Wilson v. Alexander, 428 A.2d 1089 (Vt. 1981). “They failed to pay property taxes for the tax years 1973-74 and 1974-75, and on October 20, 1976, the defendant Alexander, tax collector for the town of Middlesex, held a tax sale pursuant to 32 V.S.A. § 5252. Plaintiff-appellee Wilson purchased the premises subject to the…”
Dike v. McCormick, 264 A.2d 769 (Vt. 1970). “It is uncontroverted that the plaintiff did not receive notice of the pending sale as required by 32 V.S.A. § 5252. It was this circumstance that undoubtedly prompted the chancellor’s order of discontinuance of the tax sale.”
Hale Resources, LLC v. Peter Levin (Vt. 2022). · cites it 4× “It noted that due process does not require actual notice of a tax sale, and the version of 32 V.S.A. § 5252 in effect at the time required only written notice by registered mail of the date and location of the tax sale to be sent to the last known address of the delinquent…”
Rote v. Town of Concord (Vt. Super. Ct. 2025). · cites it 3× “32 V.S.A. § 5252(a) (“When . . . the taxpayer is delinquent for a period longer than one year, the collector may extend a warrant on such land.”
GMAC Mortg., LLC v. Winston Jennison Invs., LLC (Vt. Super. Ct. 2013). · cites it 4× “See 32 V.S.A. § 5252. Nonetheless, on March 23, 2010, the tax collector for the Town of Sutton sold the property to WJI at auction for $6,714.”
Emanuel G. Contos v. Town of Londonderry & Sandra Superchi (Vt. 2023). · cites it 2× “Plaintiff alleged that the Town failed to comply with 32 V.S.A. § 5252 because it mailed the tax sale notice to the wrong address and did not publish the notice in a newspaper of sufficient circulation; that the inadequate notice deprived him of due process; and that the Town…”
Gray-Quintin v. Town of Williamstown (Vt. Super. Ct. 2012). · cites it 3× “More specifically, the case provides an opportunity to clarify the steps that must be taken when a town sends timely notice of a pending tax sale to the taxpayer by certified mail pursuant to 32 V.S.A. § 5252(3), but then learns, one day before the scheduled sale, that the…”
Show all 13 citing cases →
— Vt. Stat. Ann. tit. 32, § 5252(1) — 2 cases
Chester Motors, Inc. v. Koledo, 503 A.2d 551 (Vt. 1985). “The appellant contends that this reference to the inapplicable warranty deed makes the tax sale void, because the notice of sale contains an ambiguity and therefore doesn’t comply with 32 V.S.A. §§ 5252, 5253. However, 32 V.S.”
GMAC Mortg., LLC v. Winston Jennison Invs., LLC (Vt. Super. Ct. 2013). “See 32 V.S.A. § 5252. Nonetheless, on March 23, 2010, the tax collector for the Town of Sutton sold the property to WJI at auction for $6,714.”
— Vt. Stat. Ann. tit. 32, § 5252(3) — 3 cases
Hogaboom v. Jenkins v. Town of Milton, 2014 VT 11 (Vt. 2014). “The trial court denied the summary judgment motions, concluding that although the Town complied with the statutory notice requirements of 32 V.S.A. § 5252, the Town failed to provide sufficient notice to taxpayer to satisfy the constitutional requirement of due process.”
Gray-Quintin v. Town of Williamstown (Vt. Super. Ct. 2012). “More specifically, the case provides an opportunity to clarify the steps that must be taken when a town sends timely notice of a pending tax sale to the taxpayer by certified mail pursuant to 32 V.S.A. § 5252(3), but then learns, one day before the scheduled sale, that the…”
Gray-Quintin v. Town of Williamstown (Vt. Super. Ct. 2012).
— Vt. Stat. Ann. tit. 32, § 5252(4) — 1 case
Ran-Mar, Inc. v. Town of Berlin, 2006 VT 117 (Vt. 2006). “The Town notes, however, that notice of the sale must also be given to each “lien holder of record,” 32 V.S.A. § 5252(4), and that this must mean that the lien holders have a sufficient interest to also give them the right to redeem.”
— Vt. Stat. Ann. tit. 32, § 5252(a) — 1 case
Rote v. Town of Concord (Vt. Super. Ct. 2025). “32 V.S.A. § 5252(a) (“When . . . the taxpayer is delinquent for a period longer than one year, the collector may extend a warrant on such land.”
— Vt. Stat. Ann. tit. 32, § 5252(a)(1) — 1 case
Rote v. Town of Concord (Vt. Super. Ct. 2025). “32 V.S.A. § 5252(a) (“When . . . the taxpayer is delinquent for a period longer than one year, the collector may extend a warrant on such land.”
— Vt. Stat. Ann. tit. 32, § 5252(a)(2) — 2 cases
Johnathan J. Billewicz v. Town of Fair Haven, 2021 VT 20 (Vt. 2021). “Just so here: plaintiffs’ suit seeking to void the tax collector’s deeds on grounds that he failed to record a report of his doings as required by § 5255 is barred under § 5294(4)’s one-year limitation period because they commenced their action more than a year after the levy.”
Rote v. Town of Concord (Vt. Super. Ct. 2025). “32 V.S.A. § 5252(a) (“When . . . the taxpayer is delinquent for a period longer than one year, the collector may extend a warrant on such land.”
— Vt. Stat. Ann. tit. 32, § 5252(a)(3) — 2 cases
Hale Resources, LLC v. Peter Levin (Vt. 2022). “It noted that due process does not require actual notice of a tax sale, and the version of 32 V.S.A. § 5252 in effect at the time required only written notice by registered mail of the date and location of the tax sale to be sent to the last known address of the delinquent…”
Emanuel G. Contos v. Town of Londonderry & Sandra Superchi (Vt. 2023). “Plaintiff alleged that the Town failed to comply with 32 V.S.A. § 5252 because it mailed the tax sale notice to the wrong address and did not publish the notice in a newspaper of sufficient circulation; that the inadequate notice deprived him of due process; and that the Town…”
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