MEMORANDUM OF DECISION ON DEBTOR'S MOTION TO AVOID LIENS
CAROL J. KENNER, Bankruptcy Judge.
The issues presented here are (i) whether a debtor may rely on her non-debtor spouse's declaration of homestead to claim real property held by them as tenants by the entirety exempt under Massachusetts General Laws ch. 188 § 1, and, (ii) if so, is a judicial lien that is only against the interest of the non-debtor spouse in the real property "a lien on...
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