72 Pa. Stat. § 1401
All State taxes imposed under the authority of any law of this Commonwealth, now existing or that may hereafter be enacted, and unpaid bonus, penalties, and all public accounts settled, assessed or determined against any corporation, association, or person, including interest thereupon, shall be a first lien upon the franchises and property, both real and personal, of such corporation, association, or person, from the date of settlement, assessment or determination, except as otherwise expressly provided by law under which the claim of the Commonwealth arises, and whenever the franchise or property of a corporation, association, or person shall be sold at a judicial sale, all taxes, interest, bonus, penalties, and public accounts due the Commonwealth shall first be allowed and paid out of the proceeds of such sale before any judgment, mortgage, or any other claim or lien against such corporation, association, or person, except as otherwise expressly provided by law under which the claim of the Commonwealth arises: Provided, however, Where the lien of a ground rent, mortgage, or other lien created by or entered against a predecessor in title to such corporation, association, or person, or of any mortgage or other lien to which priority over the Commonwealth's lien is allowed by the provisions of the law under which the claim of the Commonwealth arises is discharged by a judicial sale, the lien of the Commonwealth shall be transferred from the property sold to the fund realized from the sale, and the purchaser shall take free of the lien of the Commonwealth, notwithstanding that the fund may be insufficient to pay all or any part of the same, unless such sale is upon a lien subordinate to the Commonwealth's lien in which case the Commonwealth's lien to the extent not paid from the proceeds shall continue in full force and effect. On distribution of the fund, the Commonwealth's lien shall be postponed in payment to said lien or liens created by or entered against such predecessor in title or other mortgagee or lien holder having priority as aforesaid, but shall not be postponed in payment to local taxes or municipal claims, except as otherwise expressly provided by law under which the claim of the Commonwealth arises: Provided further, That the Department of Revenue, with the approval of the Attorney General and Auditor General, may release from the lien of such taxes, such part or parts of the real property of any corporation, as may be requested by such corporation or owners or lien creditors thereof, upon payment of such proportionate part of the taxes due as the value of the real property released bears to the value of all the real property bound by such lien, except in cases where the value of the real property requested to be released is less than the proportionate share of the taxes due, then upon payment of such portion of the taxes due as may be deemed equitable by the Department of Revenue, with approval of the Attorney General and Auditor General, not exceeding, however, the value of the real property requested to be released, and the department shall furnish the person or corporation paying such tax with a certificate showing the property released, which certificate may be recorded in the office of the recorder of deeds of the county in which the land lies. But the lien of transfer inheritance taxes shall be limited to the property chargeable therewith, and, unless such taxes shall be sued for within five years after they are due, they shall cease to be a lien as against any purchaser of real estate.
72 P.S. § 1401