OPINION
This case presents a question of first impression — whether the California Franchise Tax Board’s claim for unpaid California personal income taxes, recorded as provided in the California Code, is a perfected lien upon personal property of a bankrupt taxpayer, and entitled to priority under 11 U.S.C. § 107(c)(3), or is insufficiently perfected and thus not good against the trustee or creditors under 11 U.S.C. § 107(c)(1)(B). The referee and the district court held that the lien was not sufficiently perfected. We affirm.
The stipulated facts are as follows: The bankrupt incurred a California personal income tax liability for 1962 which was never satisfied. On December 15, 1966, some two-and-one-half months before the petition in bankruptcy was filed, the Franchise Tax Board (FTB) recorded a tax certificate with the Los Angeles County Recorder pursuant to Cal.Rev. & Tax.Code §§ 18881, et seq. (West 1970). Section 18882 of that Code provides:
“From the time of filing for recording the amount of tax, interest, and penalty set forth .constitutes a lien upon all property of the taxpayer in the county, owned by him or afterward and before the lien expires acquired by him. The lien has the force, effect, and priority of a judgment lien and continues for 10 years from the date of the recording unless sooner released or otherwise discharged.”
We agree with the FTB that it did acquire a lien upon both the real property (if any — -here there was none), and the personal property of the taxpayer. The phrase “all property” is broad enough to cover both types of property, and we see no reason to give it a narrower meaning.
That conclusion, however, does not solve our problem. The lien must be “perfected or enforceable at the date of the bankruptcy against one acquiring the rights of a bona fide purchaser on that date, whether or not such purchaser exists” (11 U.S.C. § 107(c)(1)(B)). The California statute provides that “[the] lien has the force, effect, and priority of a judgment lien” (§ 18882). In California, a recorded judgment creates a lien, good against bona fide purchasers, only upon the debtor’s real property; the levy of a writ of execution is required to bind the debtor’s personal property in a manner that is effective against bona fide purchases. C,al. Code Civ.Proc. § 674 (West Supp.1972); Miller v. Bank of America, 9 Cir., 1948, 166 F.2d 415, 417-419. Without such a levy, the lien of the judgment on personal property has no “force, effect [or] priority” against bona fide purchasers. Thus the California definition of the lien, and particularly of its “force, effect and priority,” makes it clear that, so far as personal property is concerned, the lien is not “perfected or enforceable” at the date of bankruptcy as required by 11 U.S.C. § 107(e)(1)(B). The FTB could have perfected its lien by going further and issuing and levying a warrant for the collection of the tax, which has the force and effect of a writ of execution. Cal.Rev. & Tax.Code § 18907 (West 1970). This the FTB did not do.
To counteract this seemingly obvious result, the FTB points to certain other California statutes, arguing that they show that, in enacting § 18882, the legislature intended to create a lien on the taxpayer’s personal property that is good against bona fide purchasers.
First, FTB points to Cal.Rev. & Tax. Code § 6757 (West 1970) relating to de*86linquent sales and use taxes. Before 1957, this section provided for the recording of a lien, which would attach to “all the real property” of the taxpayer. In that year the language was changed to read “all property,” as does'§ 18882. Both sections retain the same definition of’the “force, effect, and priority” of the lien as that of a judgment lien. However, there was added at the end of the section:
“The lien imposed by this section shall not be valid insofar as personal property is concerned as against a purchaser for value without actual knowledge of the lien.”
Nothing comparable appears in § 18882.
Cal.Unemp.Ins.Code § 1703 (West 1972) has a similar history and similar language, including a proviso reading:
' “[Ejxcept that with respect to personal property the lien shall not be valid against a purchaser for value without actual knowledge of the lien.”
In 1969, the California legislature enacted the following provision as Cal. Unemp.Ins.Code § 1703.5 (West 1972), Cal.Rev. & Tax.Code § 6757.5 (West 1970), and Id. § 18882.5:
“The board may also file a certificate of state tax lien with the Secretary of State.....From the time of filing of the certificate with the Secretary of State, the amount required to be paid, together with interest and penalty constitutes a lien upon all personal property in the state owned by the person or afterwards acquired by him until the certificate of state tax lien lapses. The lien has the force, effect and priority of a judgment lien.”
Again, a proviso was added to the sales and use tax (§ 6757.5) and unemployment compensation tax (§ 1703.5) Code sections, but not to the one applicable to personal income tax (§ 18882.5):
“A lien imposed by this section shall not be valid “as against a purchaser for value without actual knowledge of the lien.”
The FTB urges that we should conclude from this history, first, that “all property” was intended to and does mean both real and personal property, and second, that the exceptions in the sales and use tax and in the unemployment compensation tax sections indicate that the legislature believed that, without them, the liens would be good against bona fide purchasers of personal property, and that the absence of such an exception in §§ 18882 and 18882.5 indicates that the liens under those sections were meant to be, and are, good against bona fide purchasers of personal property.
The first argument, we can and do accept. The second, however, does not persuade us. Each of the statutes that the FTB cites defines the “force, effect, and priority” of the lien as that of a judgment lien. As we have seen, such a lien, until enforced by levy, is not good against bona fide purchasers of personal property. Thus the provisos in favor of such purchasers in the sales tax and unemployment compensation tax sections are perfectly consistent with the defined “force, effect, and priority” of the liens. The provisos are unnecessary and redundant. They may well have been added out of an abundance of caution; there is no legislative history to tell us why they are there. We cannot translate the absence of such provisos in §§ 18882 and 18882.5 into a determination by the legislature that the definition of the “force, effect, and priority” of the liens in those sections means something different from what it says.
Affirmed.