The qualified heir is personally liable for the additional tax imposed under this article. The amount of the adjusted tax difference attributable to an interest in any qualified property, computed in the same manner as provided in Internal Revenue Code Section 2032A(c)(2)(C) is a lien on the interest in the property in favor of this State. The lien arises at the time the election is filed hereunder and continues until:
(1) the liability for tax under this article attributable to the interest has been satisfied or has become unenforceable by lapse of time; or
(2) it is established to the satisfaction of the department that no further tax liability attributable to the interest may arise under this article.