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.
Maryland Legal Code