In a recent case, the First Circuit Court of Appeals has ruled that a debtor, a co-owner of real property, can remove a taxing authority's lien on the totality of the jointly owned land by confirmation of his chapter 13 plan. In this case, the Court focused on Mass. law which allows one lien on a single piece of land, no matter if that land is jointly owned. Thus, the debtor's plan which provided for a lifting of all liens on the land once the debtor made his final payment did indeed act to lift the lien as to all owners. "While the Town might argue that the loss of their lien, as to non-debtor co-owners, is harsh and unfair, such a result is mandated by Massachusetts' unitary lien law as set forth in Curtiss v. Sheffield." Here is a link to the entire case: http://www.bap1.uscourts.gov/cgi-bin/bpgetopn.pl?OPINION=05-064P Mike