In re Agriprocessors, Inc., 465 B.R. 822 (Bankr. N.D. Iowa 2012)

(purchasing party of Agriprocessors’ real property during bankruptcy proceedings received court order approving sale free and clear of all liens; county held tax lien on property but was not listed as creditor and did not receive notice of bankruptcy; county brought proceedings against purchaser to set aside the order approving the sale; ruling on summary judgment, court held county did not have actual notice of bankruptcy proceedings to defeat lack of procedural due process required to protect rights; purchaser not bona fide purchaser because had knowledge of tax lien; remedy must be determined at trial because questions of fact remained regarding purchaser’s expectations at sale and whether bankruptcy trustee agreed to pay tax liens).

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