In Old Bridge Owners Co-op. Corp. v. Township of Old Bridge, 914 F. Supp. 1059 (D.N.J.1996), the FDIC and RTC held mortgages on real property as receivers of the first and second mortgagees. Old Bridge, supra, 914 F. Supp. at 1062. Tax liens arose against the property for unpaid taxes during the years the property was in receivership. Id. at 1063. The plaintiffs, who acquired their interests in the property from the federal receivers, relied on 12 U.S.C.A. 1825 to argue that the tax liens were void as a matter of law. Ibid. The federal court first noted that, under the statute, the FDIC remained liable for property taxes assessed against any real property in which it had an interest. That is, real property taxes assessed against the property owner while a property was in federal receivership accrued and were the statutory responsibility of the FDIC. Old Bridge, 914 F. Supp. at 1064. The federal court turned next to the more difficult question of whether the property, while in federal receivership, may be encumbered by liens for these debts. The federal court looked to New Jersey tax law, specifically N.J.S.A. 54:5-6, which provides that taxes on lands "shall be a lien on the land on which they are assessed." Ibid. Since 12 U.S.C.A. 1825(b)(2) provided that no involuntary lien shall attach to the FDIC's property, any delinquency arising prior to the federal receivership, liens would attach and run with the land. Id. at 1065. However, the judge reasoned that subsection (b)(2) protected the federal interest by precluding the foreclosure of the property to satisfy such a lien without the FDIC's consent. Ibid. With respect to delinquent taxes that arose when the property was held by a federal receiver, the Old Bridge court framed the question as follows: Stated in greater detail, the question is whether a lien arises, but achieves only an inchoate status until the FDIC transfers its interest, when the lien would then become choate; or whether a lien fails to arise at all and the property is transferred free of the delinquency with the taxes and charges retaining the status of unpaid debts. If the former, the delinquency "runs with the land," if the latter, the creditor's only recourse is against the debtor (or the FDIC in personam) and not against the property itself. Ibid.