Cf. In re Reamy, 169 B.R. 352 (Bankr. D. Md. 1994), regarding the difference in treatment of tax liability when real property is transferred, citing Md. Tax Code § 14-805(a). The semiannual date of finality.
Md. Code Ann. Tax-Prop. § 10-102(a)(2001). See also In re Reamy, 169 B.R. 352, 353 (Bankr. D. Md. 1994). Generally speaking, and with numerous exceptions, allowable claims are restricted to prepetition debts.
Coinciding with the July 1 due date, "liability for the tax and a 1st lien attaches to the personal property in the amount of the property tax due on the personal property." Md.Tax-Prop. Code Ann. §§ 14-805(b) and 14-804(b); see In re Sylvia Dev. Corp., 178 B.R. 96 (Bankr.D.Md. 1995); In re Reamy, 169 B.R. 352 (Bankr.D.Md. 1994). C
Federal courts have concluded that the real property tax lien in Maryland arises on July 1 of the tax year. See Maryland Nat'l Bank v. Mayor City Council of Baltimore, 723 F.2d 1138, 1141 (4th Cir. 1983); In re Sylvia Dev. Corp., 178 B.R. 96 (Bkrtcy.D.Md. 1995); In re Reamy, 169 B.R. 352 (Bkrtcy.D.Md. 1994). Chevy Chase's analogy to real estate taxes benefits it, but only as to that aspect of the Shore Lien which gives to an unpaid current installment of the benefit assessment a priority that is senior to all but "prior State, county, or municipal real property taxes."
Like unpaid taxes on real property, a delinquent benefit charge on real property is a lien on the property from the date it becomes payable until the date it is paid and is a first lien. See T–P § 14–804(a) ; T–P § 14–805(a) ; In re Reamy , 169 B.R. 352, 353 (Bankr.D.Md.1994) (In Maryland, property taxes only become a lien against the property of the owner when they are due and unpaid.). If the benefit charge remains unpaid, the property is put up for sale by the tax collector.