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 to a 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?

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