Maryland Tax - General Section 13-802

      If the transferee or auctioneer in a bulk transfer fails to file the notice required in § 11-505 of this article or to retain consideration in an amount equal to the claim of the Comptroller for unpaid sales and use tax:

            (1)      any consideration in the bulk transfer is subject to a first priority right and lien for any sales and use tax that the transferor owes to the State; and

            (2)      the transferee or auctioneer is personally liable for the sales and use tax, interest and penalties that the transferor owes to the State.