tax rolls. Delinquent lands are sold for taxes, and titles are to be built up and perpetuated on such sales. When lands are offered at tax sales, it is important to the public revenue, as well as to purchasers, that some definitely ascertained tract or tracts should be put up for sale. There would be little inducement to buy if the parcels offered are not pointed out by some apt and suitable description familiar to the public, which would enable a purchaser to identify, not merely a tract, but the particular parcel purchased. Bidzwell v. Webb, 10 Minn. 59, (Gil. 41;) Black, Tax Titles, § 38; 1 Desty, Tax’n, 564. To us the proposition that fractions of whole sections need not be designated in a tax roll further than by giving the section, town, range, and number of acres, in connection with the owner’s name, is novel, and somewhat startling. Our observation and study have led us to believe that the practice of describing parts of sections in tax rolls, as well as in deeds of conveyance, is universal at the west. We are certain that the statute in force when these lands were assessed required such descriptions in addition to the other data mentioned. Comp. Laws, § 1582; also Id. § 1544. Section 1582 provides that the assessment roll, among other things, shall contain a list of lands, “with the number of acres in each tract set opposite the same.” To set the number of acres down in the roll opposite the tract necessitates a description of the tract in connection with the number of acres. We think this statute is not only plain, but is likewise mandatory. It is well settled that a description in a tax proceeding—which is a proceeding in invitum —that is inherently and fatally defective cannot be helped out and validated by extrinsic evidence. It is also true that where premises have acquired a name or description by repute, though not technically correct, the same will suffice for purposes of taxation, and parol evidence is competent to show the name acquired by repute coincides with the proper description of such land. Gilfillan v. Hobart, 34 Minn. 67, 24 N. W. Rep. 342. This line of authority is clearly not in point in the case at bar. There is neither allegation in the answer nor claim that the lands of the
