(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.