A owns 100% surface and 100% minerals of a tract of land in Colorado. Colorado taxes severed mineral interests. A conveys to B reserving 1/2 of the minerals for a period of 25 years and as long thereafter as oil/gas are being produced. The interest is to automatically revert to the B or B’s successors and assigns after the 25 years is up. After 20 years, A fails to to pay the taxes and the mineral interest is sold at a tax sale. A deed for the 1/2 mineral interest is granted to the purchaser, C. Did C acquire just the remainder of the 25 year term interest, or the full and complete interest in 1/2 the minerals? There has never been any production from these minerals.
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