States, 276 U.S. 547, 555-56, 48 S.Ct. 371, 372-73, 72 L.Ed. 693 (1928), where the Supreme Court addressed the rights of a federal corporation which held a security interest in property subject to local taxation. The Court held that even where a federal instrumentality retains a mortgage interest in property, at a tax lien cannot be foreclosed so as to extinguish the FDIC’s interest in the property unless the FDIC consents). Plaintiff claims that the tax liens which arose pursuant to Mass. Gen. L. ch. 60, § 37 violate 12 U.S.C. § 1825(b)(2), which provides that no involuntary lien shall attach to the property of the FDIC. The statute “denies authorities the ability to lien a FDIC property as a vehicle for collection for delinquent tax.” FDIC v. Lowery, 12 F.3d 995, 997 (10th Cir.1993) (<HOLDING>). The sticky issue here is that the FDIC has
holding that the mortgagee named in the mortgage at the time of the mortgages execution acquired the legal title to the property holding that no tax liens may attach to property after the fdic acquired title holding that congress has made it clear in amending section 522 that a lien will be deemed to impair an exemption even when there is no equity in the property if the sum of all the liens on the property and the hypothetical value of the exemption without liens exceeds the value of the debtors interest in the property in the absence of liens holding that federal government may not under michigan law attach lien to entireties property to satisfy individual tax liability of one spouse holding that under michigan law tenants in the entirety possess sufficient property interests for federal tax liens to attach