§ 1137. Statute of limitations. Every deed given pursuant to the
provisions of this article shall be presumptive evidence that the
proceeding and all proceedings therein and all proceedings prior thereto
from and including the assessment of the real property affected and all
notices required by law were regular and in accordance with all
provisions of law relating thereto. After two years from the date of the
recording of such deed, the presumption shall be conclusive. No
proceeding to set aside such deed may be maintained unless the
proceeding is commenced and a notice of pendency of the proceeding is
filed in the office of the proper county clerk prior to the time that
the presumption becomes conclusive.