Argued and Submitted October 10, 2000 — Pasadena, California
OPINION
BOOCHEVER, Circuit Judge:
We decide whether the Federal Deposit Insurance Corporation ("FDIC"), when it acts as receiver, can avoid liens on real property securing delinquent tax penalties, when the liens were imposed before the FDIC was appointed receiver. We also determine whether the FDIC must pay California redemption charges and "Mello-Roos" taxes.
FACTS
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