Section 13-805 - Unpaid tax(a) Unpaid tax, interest, and penalties constitute a lien, in favor of the State, extending to all property and rights to property belonging to: (1) the person required to pay the tax; or(2) the fiduciary estate on which the tax is imposed.(b) Unpaid inheritance tax, interest, and penalties constitute a lien, in favor of the State, extending to: (1) the assets of a small business for which an alternative payment schedule was granted under § 7-218 of this article; and(2) any other property on which inheritance tax is due.(c) Unpaid Maryland estate tax and interest constitute a lien, in favor of the State, extending to the estate that is subject to the Maryland estate tax.(d) Unpaid Maryland generation-skipping transfer tax and interest constitute a lien, in favor of the State, extending to any property included in the generation-skipping transfer for which the Maryland generation-skipping transfer tax is due.