Did the Second Circuit err in refusing to extend the holding of BFP to a lawfully conducted tax foreclosure?

QUESTION PRESENTED BFP v. Resolution Trust Corp., 511 U.S. 531 (1994) (“BFP”) held the auction price obtained at a mortgage foreclosure conducted in accordance with the statutory requirements of state law constitutes “reasonably equivalent value” in the context of a fraudulent conveyance action under 11 U.S.C. § 548 of the Bankruptcy Code. The question presented here is: did the Second Circuit err in refusing to extend the holding of BFP toa lawfully conducted tax foreclosure, where New York tax foreclosure law provides for ample notice, opportunity to cure and judicial oversight of the process, and where there is no evidence of a clear and manifest intent by Congress to allow 11 U.S.C. § 548 to impinge upon the important state interests in securing real estate titles and collecting real property taxes? i PARTIES TO PROCEEDINGS AND RELATED CASES The parties to these proceedings are identified on the front cover. Related cases are denominated as follows: 1) Gunsalus v. County of Ontario, United States Court of Appeals for the Second Circuit, Case No. 203865-bk. Judgment entered June 27, 2022. 2) Hampton v. County of Ontario, United States Court of Appeals for the Second Circuit, Case No. 203868-bk. Judgment entered July 5, 2022. 3) Gunsalus v. County of Ontario, United States District Court for the Western District of New York, Case No. 20-CV-6134-F PG. Judgment entered June 25, 2020. 4) Hampton v. County of Ontario, United States District Court for the Western District of New York, Case No. 20-CV-6135-F PG. Judgment entered June 25, 2020. 5) Gunsalus v. County of Ontario, United States District Court for the Western District of New York, Case No. 17-CV-6810-F PG. Judgment entered July 18, 2018. 6) Hampton v. County of Ontario, United States District Court for the Western District of New York, Case No. 17-CV-6808-F PG. Judgment entered July 18, 2018. 7) Gunsalus v. County of Ontario, United States Bankruptcy Court for the Western District of New York, AP No. 17-2008-PRW. Judgment on the issues presented to this Court entered November 6, 2017. Final judgment entered February 19, 2020. 8) Hampton v. County of Ontario, United States Bankruptcy Court for the Western District of New York, AP No. 17-2009-PRW. Judgment on the issues presented to this Court entered November 6, 2017. Final judgment entered February 19, 2020. 9) In Re Brian L. Gunsalus and Gliee V. Gunsalus, United States Bankruptcy Court for the Western District of New York, BK No. 2-17-20445 (Chapter 13). Judgment on the issues presented to this Court entered November 6, 2017. Final judgment entered February 19, 2020. 10) In Re Joseph M. Hampton and Brenda S. Hampton, United States Bankruptcy Court for the Western District of New York, BK No. 2-17-20459 (Chapter 13). Judgment on the issues presented to this Court entered November 6, 2017. Final judgment entered February 19, 2020.