Whenever any estate is liable to pay a tax, the amount of the tax, including any interest or addition to the tax, is a lien in favor of the state of North Dakota on the real and personal property of the estate from the time the tax commissioner files a notice of estate tax lien with the recorder of a county in which the real or personal property is situated. If the real or personal property is conveyed or transferred by the estate before the tax commissioner files a notice of estate tax lien, the tax, and any interest or addition to the tax, is a liability of the beneficiaries of the estate under the provisions of section 57-37.1-09 and the liability becomes a lien upon the property of the beneficiaries named in the notice of estate tax lien.