In Casino Reinv. Dev. Auth. v. Cohen, 321 N.J. Super. 297, 728 A.2d 868 (Law Div.1998), Judge Williams first noted that the phrase "property of the Corporation" may refer to either fee ownership of real estate by the FDIC or the holding of a lien interest. Turning to the question whether a lien under New Jersey tax law could attach to real property during the period a federal receiver held a mortgage, Judge Williams concluded that a "facial reading" of the federal statute "would suggest that the decision is self-evident." Ibid. Under New Jersey tax law, a lien for unpaid taxes attaches to the real estate itself. He reasoned that where the federal receiver never acquires an ownership interest in the real estate and the title to the fee never becomes "property of the Corporation," 1825(b)(2) does not act as a bar to attachment of a tax lien on the underlying real property during the period that a mortgage is held in federal receivership. Ibid.