GOV §7170: (a) Except as provided in subdivisions (b) and (c), a state tax lien attaches to all property and rights to property whether real or personal, tangible or intangible, including all after-acquired prop

(a) Except as provided in subdivisions (b) and (c), a state tax lien attaches to all property and rights to property whether real or personal, tangible or intangible, including all after-acquired property and rights to property, belonging to the taxpayer and located in this state. A state tax lien attaches to a dwelling notwithstanding the prior recording of a homestead declaration (as defined in Section 704.910 of the Code of Civil Procedure). (b) A state tax lien is not valid as to real property against the right, title, or interest of any of the following persons where the person’s right, title, or interest was acquired or perfected prior to recording of the notice of state tax lien in the office of the county recorder of the county in which the real property is located pursuant to Section 7171: (1) A successor in interest of the taxpayer without knowledge of the lien. (2) A holder of a security interest. (3) A mechanic’s lienor. (4) A judgment lien creditor. (c) A state tax lien is not valid as to personal property against: (1) The holder of a security interest in the property whose interest is perfected pursuant to Section 9308 of the Commercial Code prior to the time the notice of the state tax lien is filed with the Secretary of State pursuant to Section 7171. (2) Any person (other than the taxpayer) who acquires an interest in the property under the law of this state without knowledge of the lien or who perfects an interest in accordance with the law of this state prior to the time that the notice of state tax lien is filed with the Secretary of State pursuant to Section 7171. (3) A buyer in ordinary course of business who, under Section 9320 of the Commercial Code, would take free of a security interest created by the seller. (4) Any person (other than the taxpayer) who, notwithstanding the prior filing of the notice of the state tax lien: (A) Is a holder in due course of a negotiable instrument. (B) Is a holder to whom a negotiable document of title has been duly negotiated. (C) Is a protected purchaser of a security or is a person entitled to the benefits of Section 8502 or 8510 of the Commercial Code. (D) Is a purchaser of chattel paper who gives new value and takes possession of the chattel paper in the ordinary course of the purchaser’s business or a purchaser of an instrument who gives value and takes possession of the instrument in good faith. (E) Is a holder of a purchase money security interest. (F) Is a collecting bank holding a security interest in items being collected, accompanying documents and proceeds, pursuant to Section 4210 of the Commercial Code. (G) Acquires a security interest in a deposit account or in the beneficial interest in a trust or estate. (H) Acquires any right or interest in letters of credit, advices of credit, or money. (I) Acquires without actual knowledge of the state tax lien a security interest in or a claim in or under any policy of insurance including unearned premiums. (J) Acquires any right or interest in property subject to a certificate of title statute of another jurisdiction under the law of which indication of a security interest on the certificate of title is required as a condition of perfection of the security interest. (K) Is a purchaser of an instrument who would have priority under subdivision (d) of Section 9330 of the Commercial Code. (L) Is a purchaser of investment property who would have priority under paragraph (1), (3), (4), or (5) of Section 9328 of the Commercial Code. (M) A transferee of money who would take free of a security interest under Section 9332 of the Commercial Code. (5) A judgment lien creditor whose lien was created by the filing of a notice of judgment lien on personal property with the Secretary of State prior to the time the notice of state tax lien is filed with the Secretary of State pursuant to Section 7171.