city may (if state law permits) assess taxes against the owner upon the entire value of the property and enforce collection by sale of the owner’s interest in the property. See id. The Court cautioned, however, that a city is “without authority to enforce the collection of taxes thus assessed so as to destroy the preexisting federal hen.” Id. at 556, 48 S.Ct. 371. To preserve the “paramount right of the United States,” and to “meet the equities of the case” as between the city and the federal government, the Court held that a city should be enjoined from selling lots for the collection of taxes unless all that petition to quiet title deprived the FDIC of its property interests and was the “functional equivalent” of foreclosure proceedings barred by § 1825(b)(2)); Lee, 130 F.3d at 1143 (<HOLDING>); Matagorda County, 19 F.3d at 222-23 (holding
holding that while section 1825b2 does not extinguish an earlier lien or excuse the payment of a tax by the fdic it does deny the ability to use a lien on fdic property as a vehicle for collection of delinquent tax holding that the doench doctrine protects the fdic even where the fdic does not have an interest in an asset holding that where property subject to the irss timely filed lien is sold during a nonjudicial sale and the irs is not given notice of the sale the sale of the property is made subject to and without disturbing the lien holding that a lien cannot be extinguished through a tax sale without the consent of the fdic holding that a lien holder who is not served and joined as a party to a tax suit cannot have his lien extinguished by the tax sale