Riggan v. Director of Revenue

In my opinion the dormant judgment statute (K. S. A. 60-2403) applies and limits the time within which the Director of Revenue may effect collection on unpaid sales or compensating tax.

The legislature has given no clear expression on the subject. K. S. A. 79-3617 and 79-3235 both provide in part:. . The director shall have the right at any time after a warrant has been returned unsatisfied, or satisfied only in part, to issue alias warrants until the full amount of said tax is collected: . . .” (Emphasis added.)

The loose expression “at any time” used therein has entirely different…