If the owner fails to redeem, a tax deed is issued to the person who purchased the property at the public auction. D.C. Code § 47-1003 (1973); see Frassetto v. Barry, 497 A.2d 109, 111-112 (D.C. 1985). It is well settled that the District must satisfy every procedural requirement leading up to the issuance of a tax deed.
On these grounds, we can distinguish the mandatory recordation of a security interest from the mandatory recordation of a notice of a tax sale. See Frassetto v. Barry, 497 A.2d 109 (D.C.1985). The notice of the tax sale provides information, like “the amount of back taxes owed plus penalties, costs, and interest,” that directly relates to the process of foreclosing on a tax lien.
This was sufficient to challenge the tax deed and to shift the burden of demonstrating validity to the appellants. See (Michael) Jones, 829 A.2d at 199 (affidavit that notice had not been given was corroborated by envelope returned as "unclaimed"); Frassetto v. Barry, 497 A.2d 109, 114-15 (D.C. 1985) (presumption that tax deed was valid was adequately rebutted). At this point, however, allocation of the burden is of little importance because the facts have been fully developed through discovery.
II. Neither side disputes the general principle that District of Columbia law requires strict compliance with the statutes and regulations governing tax sales of real property. Keatts v. Robinson, 544 A.2d 716, 719 (D.C. 1988); Frassetto v. Barry, 497 A.2d 109, 113-14 (D.C. 1985); Robinson v. Kerwin, 454 A.2d 1302, 1306 (D.C. 1983); Boddie v. Robinson, 430 A.2d 519, 522-23 (D.C. 1981); Shenandoah Corp. v. Pringle, 385 A.2d 748, 749-50 (D.C. 1978); Potomac Bldg. Corp. v. Karkenny, 364 A.2d 809, 812 (D.C. 1976), cert. denied, 431 U.S. 921, 97 S.Ct. 2192, 53 L.Ed.2d 234 (1977). The issue here is whether that rule prohibits a deviation, in the form of an abbreviated first name, from the full name of the property owner listed in the District's tax records when the government publishes or mails the required notices during the tax sale process.
The power to convey property for nonpayment of taxes can be validly exercised only by strict compliance with the relevant statutes and regulations. Frassetto v. Barry, 497 A.2d 109, 113 (D.C. 1985); Boddie v. Robinson, 430 A.2d 519, 522 (D.C. 1981); Watson v. Scheve, 424 A.2d 1089, 1092 (D.C. 1980). Thus, if the District fails to comply with the statute and regulations, the sale is invalid and must be set aside.