§ 1168. Certificate of sale as evidence. 1. The certificate of sale or
any other written instrument representing a tax lien shall be
presumptive evidence in all courts in all proceedings by and against the
purchaser and his or her representatives, heirs and assigns, of the
truth of the statements therein, of the title of the purchaser to the
property therein described, and of the regularity and validity of all
proceedings had in reference to the taxes or other legal charges for the
non-payment of which the tax lien was sold and the sale thereof.

2. After two years from the issuance of such certificate or other
written instrument, no evidence shall be admissible in any court to
rebut such presumption unless the holder thereof shall have procured
such certificate of sale or such other written instrument by fraud or
had previous knowledge that it was fraudulently made or procured.