Tax sales are disfavored by Mississippi courts.  And because the the Courts require strict adherence to Notice requirements, property owners who have lost property to tax sales have recourse to have tax sales set aside. Mississippi Code Annotated section 27-43-3 (Supp.2009) requires that “notice be given to property owners of a tax sale before a valid tax deed may be issued to the purchaser of the subject property. Under this statute, service of notice must be made by the sheriff, and notice must also be sent by registered or certified mail.” MS Code Ann 27-43-3 (Supp. 2009) requires proper notice be delivered to property owners informing them of a pending tax sale.  If that notice is returned undelivered, the Clerk is required to have notice delivered by the Sheriff.  If that notice is returned undelivered, the clerk must conduct additional search and inquiry to determine the owners address.  If additional search and inquiry does not produce an address for the owner, the clerk must make an affidavit detailing the steps taken to ascertain the owners address.  The affidavit must be made permanent part of the tax sale record.  If the clerk fails to follow these requirements, the land owner may present that evidence in his Petition to Set Aside Tax Sale. The Mississippi Court of Appeals held that ” In Mississippi, it is public policy to favor and protect landowners from [the sale of their land] for taxes.”C.F.P. Properties, Inc. v. Roleh, Inc., 56 So.3d 575 (Miss.App. 2010) citing  Lawrence v. Rankin, 870 So.2d 673, 676 (¶ 13) (Miss.Ct.App.2004). Further, section 27-43-3 ” must be given a strict construction, and its requirements fully satisfied.” Id. at (¶ 14). Failure of the chancery clerk to file the requisite affidavits renders a tax deed void. Id. In the case of Roleh the Chancery court found for the landowner that the lack of an affidavit by the court documenting attempts to provide notice was sufficient grounds to set aside the tax sale.  On appeal, the Court of Appeals affirmed the lower court’s holding and voided the final sale of the commercial property. The Court of Appeals stated that the policy in Mississippi is to favor and protect the original landowner from sale of land for failure to pay taxes.