Law Plaintiff argues that the tax liens and tax taking under Massachusetts law are invalid under § 1825(b)(2) of FIRREA. An analysis of this question begins with City of New Brunswick v. Unite acquired title to the property, as it had in Lowery, but has a mortgage interest in it. Under Massachusetts law, an inchoate tax hen arises by statute, which recognizes it is “subject ... to any lawful action under any paramount authority conferred by the constitution or law of the United States.” Mass. Gen. L. ch. 60, § 37. Because the tax lien is made expressly subject to federal law, it cannot be said to be an involuntary lien attaching to the FDIC’s property interest created by the mortgage. But cf. Old Bridge Owners Coop. Corp. v. Township of Old Bridge, 914 F.Supp. 1059, 1064 (D.N.J.1996) (<HOLDING>). Indeed, in its own tax policy and memorandum
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