Daryl Deadbeat owes the IRS $75,000 for delinquent income taxes. He owns real property with appraised equities of $85,000. The IRS seizes the properties and sets a minimum bid price of $75,000. Because no one trusts Daryl not to start legal hassles if they buy the properties, no one shows up to bid. Finally, the United States buys the properties at the minimum bid price and credits Daryls account as being paid in full. All tax liens are released at the time of sale.

Seven months after the sale, the United States receives an offer to purchase the properties. Because oil has been discovered on one of the parcels, the offer is in the amount of $150,000. Obviously the offer is accepted and the transaction closes. Does the IRS have to share the profit on the sale with Daryl?