California Business And Professions Code Section 10239.20
Claims allowed in a proceeding under this article shall be given preference in the following order: (a) Expense of administration. (b) Taxes due to the State of California. (c) Claims having preference by the laws of the United States and by laws of this State. (d) All other claims. Upon the issuance of an order appointing a conservator or liquidator for any person under the provisions of either Sections 10239.1 or 10239.6 or both such sections, the lien of taxes due to the State of California imposed by Article 4 (commencing with Section 12491) of Chapter 4 of Part 7 of Division 2 of the Revenue and Taxation Code shall become subordinate to the reasonable administrative expenses of the proceeding under said order.