EB Dorev Holdings, Inc. v. West Virginia Department of Administration, Real Estate Division

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Respondent WVDOA bought two private properties, but failed to ensure that the prior owners paid the previously assessed real estate taxes. Eventually tax liens issued which were purchased by Petitioner EB Dorev Holdings, Inc. The WVDOA sued to stop the issuance of tax deeds to petitioner. The circuit court found that (1) the WVDOA's purchase of the properties rendered them exempt from the real estate taxes owed by the previous private owners; and (2) the tax liens had been extinguished through the doctrine of merger and/or had never matured into saleable liens because the tax liability was inchoate when the WVDOA bought the properties.