Barer

*560 Opinion

The question presented here is whether ad valorem tax liens on a possessory interest in tax-exempt (Indian) land were eliminated by a nonjudicial foreclosure sale of the possessory interest by a senior lien-holder. The trial court determined, and we agree, that the tax liens were not eliminated by the sale. Accordingly, we shall affirm the summary judgment entered in favor of the County of Riverside and the County of Riverside Tax Collector (collectively referred to as defendant) in an action for quiet title and declaratory relief brought by Charles J. Barer, as trustee for the Charles J. Barer Trust (plaintiff). Such action was brought by plaintiff as the owner of a condominium on land in Palm Springs managed by the Department of Indian Affairs (the property) which was the subject of the tax liens noted.

Factual and Procedural Background

On November 7, 1989, the owners of the property (Leslie Kay Houston and others, hereinafter referred to as Houston) executed a deed of trust imposing a lien thereon (the deed of trust) in favor of First Fidelity Thrift and Loan Association (First Fidelity).

On March 1, 1991, the 1991-1992 real property tax was assessed against…