377) Delivery of an execution creates an unperfected lien against the taxpayer's personal property, but this execution lien would have been junior to all tax liens of the DTF.
438) The legislative history simply deepens the mystery, according to which the amendment "prevents the avoidance of unperfected liens against a bona fide purchaser, if the purchaser qualifies as such under section 6323 of the Internal Revenue Code or a similar provision under state or local law.
According to Larry Highbloom, president of VINtek, 'The Dealer Monitoring Program reduces and prevents the accumulation of
unperfected liens for auto finance lenders of all sizes.
