Horney, J.,
delivered the opinion of the Court. Barnes, J., dissents. Dissenting opinion at page 662, infra.
The question presented on this appeal is whether the filing of a notice of lien for sales taxes has the force and effect of a lien of judgment against the personal property of the tax debtor absent a prior levy thereon under a writ of execution issued by the tax creditor.
The appellee (Comptroller of the Treasury of the State of Maryland) filed a lien for sales taxes with the clerk of the Superior Court of Baltimore City on January 15, 1960, against Allen Dagurt, trading as Pearl Cafe and Restaurant, in the [658]*658aggregate sum of $1112.74. The lien was based on the assessment of August 28, 1959, for the period from January 1958 through July 1958, in the sum of $912.43, including interest and penalties, and on the assessment of January 8, 1960, for the period from July 1, 1959, through November 30, 1959-, in the sum of $200.31, including interest and penalties.
The appellant (Liquor Dealers Credit Control, Inc.) obtained a summary judgment for $3280.94 and costs of suit on January 20, 1960, and forthwith directed the issuance of execution. The tax debtor executed a deed of trust for the benefit of creditors on February 15, 1960, and the equity court assumed jurisdiction over the trust estate on the following day. In May of 1960, the appellee filed its claim for sales taxes totaling $1186.29. This sum was made up of the two tax assessments aggregating $1112.74 set forth in the previously filed tax lien and an additional assessment in the sum of $73.75 made on May 11, 1960. No lien was claimed for the additional assessment. In June of 1964, the appellant filed its petition for a priority based on its judgment and execution.
The assets of the trust estate, consisting of personal property only, were sold for cash and, after payment of the trustee’s commissions, court costs and administration expenses, there was only $1542.13 for distribution tO' the creditors. The auditor allowed the whole of this sum to the judgment creditor and the tax creditor filed exceptions to the audit. The chancellor, in sustaining the exceptions, directed the auditor to restate the account by distributing $1112.74 to the tax creditor and the balance to the judgment creditor after payment of the additional costs.
A determination of the controversy as to which claimant is entitled to priority necessarily requires a construction of § 342(b)1 of Article 81 of the Code of 1957 which, as amended by Chapter 91 of the Acts of 1958, effective June 1, 1958, now provides:
“The tax, and all increases, interests and penalties thereon shall be a lien upon all the property, real [659]*659and/or personal, of any person liable to pay the same to the State from and after the time when notice has been given that such tax has become due and payable as provided herein. Notice of such lien shall be filed by the Comptroller with the clerk of the circuit court of the county in which said property is located, or if located in Baltimore City, with the clerk of the Superior Court of Baltimore City. Each clerk of court shall accurately and promptly record and index all such notices of lien filed with him by the Comptroller and shall enter such lien in the judgment docket of the court, stating the name of the delinquent taxpayer, the amount of the lien and the date thereof. The lien provided for in this section shall have THE FULL FORCE AND EFFECT OF A LIEN OF JUDGMENT. Unless another date is specified by law, the lien arising at the date of nonpayment as in this section specified and provided for, shall continue with the same force and effect as a judgment lien. Any such lien on personal property shall not be effective as against an innocent purchaser for value unless the personal property has been levied upon by an officer of a court.”
Several months before the enactment of the amendment, when the statute simply provided that the tax should be a lien on “the property” of the taxpayer, the Circuit Court for Prince George’s County (per Marbury, J.)2 had occasion to rule,3 in a case concerning a question of priority between the Comptroller of the Treasury and the United States of America, that the sales tax lien did not extend to personal property. As a result of the ruling the statute (formerly § 338) was amended by adding the italicized portions set forth above.
Although the appellant does not claim that it comes within [660]*660the exception granted by the statute to an “innocent purchaser for value” and concedes that the tax lien was properly filed prior to the time it obtained judgment and issued execution thereon, it contends that the statute did not relieve the appellee of the requirement of issuing an execution in order to perfect its lien and entitlement to priority over the appellant. We do not agree for several reasons.
In the first place, it is apparent that the legislature intended to create a perfected tax lien. The introduction of the clarifying amendment immediately after the rendition of the court ruling, together with the unequivocal declaration in the title to the bill that the tax lien should “apply to both real and personal property,” makes it clear that it was the intention of the legislature to remove all doubt that the lien attached to personal as well as real property upon the filing of notice with the clerk of court that the tax was due and payable. Any other construction would be unreasonable under the circumstances. Height v. State, 225 Md. 251, 170 A. 2d 212 (1961). In addition to this, it is just as clear that there would have been no reason to except an innocent purchaser for value from the effect of the lien if the legislature had intended that issuance of an execution was necessary in order to perfect the tax lien. As was pointed out in Smith v. Higinbothom, 187 Md. 115, 48 A. 2d 754 (1946), if a word or clause in a statute is susceptible of more than one interpretation, the court should endeavor to ascertain the legislative intention by considering the reason for the enactment and the objective intended to be accomplished and adopt the meaning which will carry out the legislative purpose.
The statutory clause (printed above in boldface) giving the lien “the full force and effect of a lien of judgment” had the effect, not of requiring the lien creditor to issue an execution in order to perfect its tax lien, but of giving the lien entered on the judgment docket the same force and effect as the lien of a judgment on which an execution had been issued. While it is generally true that the obtention of a judgment does not create a lien on the personal property of the judgment debtor, Harris v. Max Kohner, Inc., 230 Md.. 349, 352, 187 A. 2d 97 (1963), and that the lien of a judgment does not ordinarily fasten to personal property until the writ of fieri facias is de[661]*661livered to the sheriff, Prentiss Tool & Supply Co. v. Whitman & Barnes Mfg. Co., 88 Md. 240, 41 Atl. 49 (1898),4
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Horney, J.,
delivered the opinion of the Court. Barnes, J., dissents. Dissenting opinion at page 662, infra.
The question presented on this appeal is whether the filing of a notice of lien for sales taxes has the force and effect of a lien of judgment against the personal property of the tax debtor absent a prior levy thereon under a writ of execution issued by the tax creditor.
The appellee (Comptroller of the Treasury of the State of Maryland) filed a lien for sales taxes with the clerk of the Superior Court of Baltimore City on January 15, 1960, against Allen Dagurt, trading as Pearl Cafe and Restaurant, in the [658]*658aggregate sum of $1112.74. The lien was based on the assessment of August 28, 1959, for the period from January 1958 through July 1958, in the sum of $912.43, including interest and penalties, and on the assessment of January 8, 1960, for the period from July 1, 1959, through November 30, 1959-, in the sum of $200.31, including interest and penalties.
The appellant (Liquor Dealers Credit Control, Inc.) obtained a summary judgment for $3280.94 and costs of suit on January 20, 1960, and forthwith directed the issuance of execution. The tax debtor executed a deed of trust for the benefit of creditors on February 15, 1960, and the equity court assumed jurisdiction over the trust estate on the following day. In May of 1960, the appellee filed its claim for sales taxes totaling $1186.29. This sum was made up of the two tax assessments aggregating $1112.74 set forth in the previously filed tax lien and an additional assessment in the sum of $73.75 made on May 11, 1960. No lien was claimed for the additional assessment. In June of 1964, the appellant filed its petition for a priority based on its judgment and execution.
The assets of the trust estate, consisting of personal property only, were sold for cash and, after payment of the trustee’s commissions, court costs and administration expenses, there was only $1542.13 for distribution tO' the creditors. The auditor allowed the whole of this sum to the judgment creditor and the tax creditor filed exceptions to the audit. The chancellor, in sustaining the exceptions, directed the auditor to restate the account by distributing $1112.74 to the tax creditor and the balance to the judgment creditor after payment of the additional costs.
A determination of the controversy as to which claimant is entitled to priority necessarily requires a construction of § 342(b)1 of Article 81 of the Code of 1957 which, as amended by Chapter 91 of the Acts of 1958, effective June 1, 1958, now provides:
“The tax, and all increases, interests and penalties thereon shall be a lien upon all the property, real [659]*659and/or personal, of any person liable to pay the same to the State from and after the time when notice has been given that such tax has become due and payable as provided herein. Notice of such lien shall be filed by the Comptroller with the clerk of the circuit court of the county in which said property is located, or if located in Baltimore City, with the clerk of the Superior Court of Baltimore City. Each clerk of court shall accurately and promptly record and index all such notices of lien filed with him by the Comptroller and shall enter such lien in the judgment docket of the court, stating the name of the delinquent taxpayer, the amount of the lien and the date thereof. The lien provided for in this section shall have THE FULL FORCE AND EFFECT OF A LIEN OF JUDGMENT. Unless another date is specified by law, the lien arising at the date of nonpayment as in this section specified and provided for, shall continue with the same force and effect as a judgment lien. Any such lien on personal property shall not be effective as against an innocent purchaser for value unless the personal property has been levied upon by an officer of a court.”
Several months before the enactment of the amendment, when the statute simply provided that the tax should be a lien on “the property” of the taxpayer, the Circuit Court for Prince George’s County (per Marbury, J.)2 had occasion to rule,3 in a case concerning a question of priority between the Comptroller of the Treasury and the United States of America, that the sales tax lien did not extend to personal property. As a result of the ruling the statute (formerly § 338) was amended by adding the italicized portions set forth above.
Although the appellant does not claim that it comes within [660]*660the exception granted by the statute to an “innocent purchaser for value” and concedes that the tax lien was properly filed prior to the time it obtained judgment and issued execution thereon, it contends that the statute did not relieve the appellee of the requirement of issuing an execution in order to perfect its lien and entitlement to priority over the appellant. We do not agree for several reasons.
In the first place, it is apparent that the legislature intended to create a perfected tax lien. The introduction of the clarifying amendment immediately after the rendition of the court ruling, together with the unequivocal declaration in the title to the bill that the tax lien should “apply to both real and personal property,” makes it clear that it was the intention of the legislature to remove all doubt that the lien attached to personal as well as real property upon the filing of notice with the clerk of court that the tax was due and payable. Any other construction would be unreasonable under the circumstances. Height v. State, 225 Md. 251, 170 A. 2d 212 (1961). In addition to this, it is just as clear that there would have been no reason to except an innocent purchaser for value from the effect of the lien if the legislature had intended that issuance of an execution was necessary in order to perfect the tax lien. As was pointed out in Smith v. Higinbothom, 187 Md. 115, 48 A. 2d 754 (1946), if a word or clause in a statute is susceptible of more than one interpretation, the court should endeavor to ascertain the legislative intention by considering the reason for the enactment and the objective intended to be accomplished and adopt the meaning which will carry out the legislative purpose.
The statutory clause (printed above in boldface) giving the lien “the full force and effect of a lien of judgment” had the effect, not of requiring the lien creditor to issue an execution in order to perfect its tax lien, but of giving the lien entered on the judgment docket the same force and effect as the lien of a judgment on which an execution had been issued. While it is generally true that the obtention of a judgment does not create a lien on the personal property of the judgment debtor, Harris v. Max Kohner, Inc., 230 Md.. 349, 352, 187 A. 2d 97 (1963), and that the lien of a judgment does not ordinarily fasten to personal property until the writ of fieri facias is de[661]*661livered to the sheriff, Prentiss Tool & Supply Co. v. Whitman & Barnes Mfg. Co., 88 Md. 240, 41 Atl. 49 (1898),4 there was no reason why the legislature (as the Congress had previously done with respect to taxes due the federal government) could not create a tax lien in favor of the State of Maryland on personal as well as real property of a tax debtor by providing that such lien shall attach (except as to an innocent purchaser for value) upon the giving of notice to the taxpayer by the filing thereof with the clerk of court to be entered in the judgment docket.
Since a lien predicated upon the rendition or entry of a judgment did not exist at common law, a judgment is not, in and of itself, a lien on either real or personal property. The right a judgment creditor has to a lien is therefore wholly statutory. Caltrider v. Caples, 160 Md. 392, 394, 153 Atl. 445 (1931). Furthermore, a judgment creates a lien on real property (and certain leasehold estates) only because the land is made liable, formerly by statute but now by rule, to be seized and sold on execution. Messinger v. Eckenrode, 162 Md. 63, 158 Atl. 357 (1932). By the same token, an execution is a lien on personal property only because the property can be sold in satisfaction of the execution. Jordan v. Reynolds, 105 Md. 288, 66 Atl. 37 (1907). And it was said in Lee v. Keech, 151 Md. 34, 133 Atl. 835 (1926), that the statutory lien of a judgment creditor is in the nature of a remedy rather than of an estate and as such is subject to legislative control and may be changed by statute without violating any constitutional inhibition. Moreover, the statutes of some states provide for a lien on personal property upon the filing of a satutorily prescribed certification in the office of certain courts. See 2 Freeman on Judgments § 938 (5th ed.). And in this state, it has always been recognized that personal property may be sold to satisfy a lien for taxes without the formality of issuing execution. In this connection, we note in Eschbach v. Pitts, 6 Md. 71 (1854), that Chapter 63 of the Laws of 1840, authorizing the Mayor and City Council of Baltimore to provide by ordinance for the sale of real as [662]*662well as personal property for the payment of taxes was said to have had the effect of also making the taxes a lien on the realty.
The final claim of the appellant that the lower court gave retroactive effect to § 342(b) as amended by Chapter 91 of the Laws of 1958 is likewise without merit. On this point, since the basic question is whether the appellee had priority over the appellant, the record shows that the liens for taxes (both of which were assessed after the effective date of the amendment) were filed and recorded on January 15, 1960, five days before obtention of judgment and issuance of execution by the appellees on January 20, 1960.
We hold that the sales tax liens of the appellee had priority over the execution on the summary judgment of the appellant.
Order affirmed; appellant to pay the costs.