Ch. 6 LAWS OF MARYLAND

(e) (1) If the Department finds that any dealer or other person liable for the
tax imposed by this subtitle intends to depart from [this] THE State, remove [his] THE
DEALER'S OR OTHER PERSON'S property from [this] THE State, conceal [himself
or his] THE DEALER OR OTHER PERSON OR THEIR property in [this] THE
State, or do any other act tending to prejudice or render wholly or partly ineffectual
proceedings to collect the tax, the Department shall notify the dealer or other person of
its findings and demand an immediate payment of the tax, [interest] INTEREST, and
penalty.

[(1)] (2) If the amount of tax, interest, and penalty specified in the notice
of jeopardy assessment is not paid within 10 days of the service of the notice, the
Department may bring any action that [it] THE DEPARTMENT considers advisable
for the prompt collection of the tax.

[(2)] (3) If, within 10 days of the service of the notice, the person liable for
the tax files with the Department satisfactory evidence that [he] THE PERSON is not
in default in paying the tax or that [he] THE PERSON will duly return and pay the tax,
then the tax is not payable before the time otherwise required by this [part] SECTION.
However, in each case, the findings of the Department as to the responsibility of the
person liable for the tax are final and conclusive.

(f) (1) The tax imposed by this subtitle and all increases, [interests]
INTERESTS, and penalties [thereon] ON THE TAX shall become, from the time due
and payable, a personal debt of the person liable to pay the [same] TAX to the State of
Maryland. An action may be brought at any time within 3 years from the time the tax
shall be due and payable by the Department in the name of the State to recover the
amount of any taxes, [penalties] PENALTIES, and interest due under the provisions of
this subtitle, but if there is proof of fraud or gross negligence, there shall be no
limitation of the period in which the action may be brought. Proof of negligence
amounting to 25 [percent] % or more of the tax due shall be prima facie evidence of
gross negligence.

(2) The tax[,] and all increases, [interests] INTERESTS, and penalties
[thereon] ON THE TAX shall be a lien upon all the property, real [and/or] OR
personal, of any person liable to pay the [same] TAX to the State from and after the
time when notice has been given that [such] THE tax has become due and payable as
provided [herein] IN THIS SECTION. Notice of [such] THE lien shall be filed
promptly by the Department with the clerk of the circuit court of the county in which
[said] THE property is located[,] or Baltimore City. Each clerk of court [shall]
accurately and promptly SHALL record and index all [such] THE notices of lien filed
with [him] THE CLERK by the Department and shall enter [such] THE lien in the
judgment docket of the court, stating the name of the delinquent taxpayer, the amount
of the lien and the date [thereof] OF THE LIEN. The lien provided for in this section
shall have the full force and effect of a lien of judgment. Unless another date is
specified by law, the lien arising at the date of [nonpayment] NONPAYMENT, as in
this section specified and provided for, shall continue with the same force arid effect as
a judgment lien. Any [such] JUDGMENT lien on personal property [shall] IS not [be]
effective as against an innocent purchaser for [value] VALUE, unless the personal
property has been levied upon by an officer of a court.

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