Ch. 2

LAWS OF MARYLAND

the second clause of the second sentence of § 160, as
it related to a lien generally, and in part repeats
the lien provision of present ET § 5-505.

Subsection (c) of this section is new language derived
without substantive change from the first clause of
the first sentence of former Art. 62A, § 4.

In the introductory language of subsection (a)(1) of
this section, the words "extending to all property and
rights to property" are substituted for the former
references to the specific property subject to a lien,
for clarity and brevity.

Also in the introductory language of subsection (a)(1)
of this section, the former word "increases" is
deleted as included in the reference to "unpaid tax".

Also in the introductory language of subsection (a)(1)
of this section, the former reference to a "failure
... to pay" a tax, interest or penalties is deleted as
unnecessary in light of the word "unpaid".

Also in the introductory language of subsection (a)(1)
of this section, the former words "to the extent
provided in § 322 of this subtitle recoverable in the
manner therein prescribed or in the manner described
in §§ 206 to 211, inclusive, of this article" are
deleted as unnecessary in light of § 13-811 of this
subtitle.

In subsection (a)(l)(i) of this section, the reference
to a person "required to pay the tax" is substituted
for the former references to specific persons liable
for the tax.

Subsection (b) of this section is revised to apply to
all personal property. Under the former law, an
inheritance tax lien on personal property existed only
under former Art. 81, §§ 160 and 161 and not as a
general provision. The revision applies to any
inheritance tax lien against all property from the
date of distribution. When previous distinctions
between real and personal property distributions were
abolished, these provisions were overlooked. The
General Assembly may wish to consider this revision.

In subsection (c) of this section, the word "lien" is
substituted for the former word "charge" to reflect
accurately that the Maryland estate tax and interest
on that tax are a lien on the Maryland estate. As to
the lien for federal estate tax, see § 6324 of the
Internal Revenue Code.

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