Docket No. 89098-Agenda 27-September 2000.

PHOENIX BOND & INDEMNITY COMPANY, et al., Appellees, 
v. MARIA PAPPAS, Cook County Treasurer and ex-
officio County Collector of Cook County, Appellant.

Opinion filed December 1, 2000.

CHIEF JUSTICE HARRISON delivered the opinion of thecourt:

This litigation challenges a rule promulgated by the CookCounty collector regarding the acceptance of penalty bids at theCounty's annual tax sale. On cross-motions for summaryjudgment, the circuit court of Cook County found the rule invalidand permanently enjoined its enforcement. The appellate courtreversed. 309 Ill. App. 3d 779. We granted leave to appeal (177 Ill.2d R. 315) and now affirm the appellate court's judgment.

The procedures governing tax sales are set forth in article 21,division 4, of the Property Tax Code (35 ILCS 200/21-190 et seq.(West 1996)). That statute provides that after judgment has beenrendered against property for nonpayment of taxes and therequisite notice has been issued, the county collector is to offer theproperty for sale at a public sale. 35 ILCS 200/21-190 (West1996). Once the property is sold, the county clerk issues acertificate of purchase to the buyer, countersigned by the collector,describing the property; indicating the date of sale and the amountof taxes, special assessments, interest and costs for which theproperty was sold; and confirming that payment of the sale pricehas been made. 35 ILCS 200/21-250 (West 1996).

Issuance to a tax buyer of a certificate of purchase fordelinquent taxes does not affect the delinquent property owner'slegal or equitable title to the property. See In re Petition of ConradGacki Profit Sharing Fund for Tax Deeds, 261 Ill. App. 3d 982,984 (1994). The owner or person interested in the property, otherthan an undisclosed beneficiary of an Illinois land trust, has theright to redeem the property from the sale. 35 ILCS 200/21-345(West 1996); Ill. Const. 1970, art. IX,