The following excerpt is from United States v. CERTAIN PARCELS OF LAND, ETC., 85 F. Supp. 986 (S.D. Cal. 1949):
It will thus be seen that the assignee of a certificate of purchase is not aided by the rule protecting bona fide purchasers for value, because he is not the purchaser of the legal title but acquires an equity merely. See also Hawley v. Diller, 178 U.S. 476, 20 S.Ct. 986, 44 L.Ed. 1157, as to what constitutes being a bona fide purchaser for value.
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