ACOBA, Judge.
We hold in this appeal from the award of title by the land court (the court) to Petitioners-Appellees Roland Hideo Higashi, Clifton Kenichi Tsuji, Kenneth Kenichi Tanaka, and Howard Jitsuo Mimaki, purchasers at a United States Internal Revenue Service (IRS) real property tax sale under 26 U.S.C. § 6337(b) (1988) (hereinafter referred to collectively as Purchasers or the Purchasers) that the court erred in ruling that the attempt by the owner, Respondent...
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