| 1. Filing. If any tax imposed by this Title or imposed by |
any other provision of law and authorized to be collected by the |
bureau is not paid when due and no further administrative or |
judicial review of the assessment is available pursuant to law, |
the assessor may file in the registry of deeds of any county or |
in the office in which a financing statement with respect to |
tangible personal property is properly filed with Title 11, |
section 9-401, subsection (1), paragraph (b) a notice of lien |
specifying the amount of the tax, interest, penalty and costs |
due, the name and last known address of the person liable for the |
amount and, in the case of a tax imposed by this Title, the fact |
that the assessor has complied with all the provisions of this |
Title in the assessment of the tax. The lien arises at the time |
the assessment becomes final and constitutes a lien upon all |
property, whether real or personal, then owned or thereafter |
acquired by that person in the period before the expiration of |
the lien. The lien imposed by this section is not valid against |
any mortgagee, pledgee, purchaser, judgment creditor or holder of |
a properly recorded security interest until notice of the lien |
has been filed by the assessor, with respect to real property, in |
the registry of deeds of the county where such property is |
located and, with respect to personal property, in the office in |
which a financing statement for such personal property is |
normally filed. Notwithstanding this subsection, a tax lien upon |
personal property does not extend to those types of personal |
property not subject to perfection of a security interest by |
means of the filing under Title 11, sections 9-104, subsection |
(7); 9-104, subsection (12); 9-302, subsection (3); and 9-304. |