July 27, 2018 Tax Foreclosure in New York Can Be a Fraudulent Transfer, District Judge Says The Supreme Court’s BFP opinion on mortgage foreclosures held not applicable to tax foreclosures in New York. 2nd Circuit , New York , New York Western District , November 22, 2016 New York Stands Alone by Not Requiring Delivery to Transfer a Note and Mortgage District judge makes an ‘Erie’ guess on an undecided issue of New York law. 2nd Circuit , New York , New York Western District ,