Peterson

Leland McCoy was the record owner of two parcels of real property in the County of Los Angeles which in July of 1976 were deeded to the State of California as a result of the owner’s failure over a period of time to pay property taxes levied thereon. (See Rev. & Tax. Code, §§ 3351, 3361, 3511.)

On May 12, 1977, McCoy conveyed his interest in the realty to respondent A. E. Sandorf, Inc., by grant deed recorded January 20, 1978.

On February 1,1978, the county purported to sell the parcels to appellants at public auction.

Prior thereto and on January 23, 1978, respondent First American Title Company of Los Angeles, on behalf of Sandorf, caused to be delivered to the county checks for the full amount of unpaid taxes, interest and penalties necessary to redeem the properties. (See Rev. & Tax. Code, § 4101 et seq.) For reasons not wholly apparent, however, the moneys submitted went so far unacknowledged as to permit the February 1 sale to appellants.

When the county subsequently concluded Sandorf had in truth redeemed the parcels prior to the auction, it declined to convey them to appellants. The latter, *112 in turn, then brought suit to quiet title and for specific…