Any tax or penalty due the state from a taxpayer is a lien in favor of the State of South Dakota upon all property and rights to property, whether real or personal, belonging to the taxpayer. In order to preserve the lien against subsequent mortgages, purchasers, or judgment creditors for value and without notice of the lien, on any property situated in a county, the department may file with the register of deeds of the county, in which the property is located, a notice of the lien in such form as the department elects.
SDCL 50-11-21.2