Marine Midland Bank-Central v. Gleason

OPINION OF THE COURT

Memorandum.

The order of the Appellate Division should be affirmed, with costs.

Although we agree with the result reached below, we take this occasion to clarify the procedural steps necessary to convert a State tax warrant into a perfected lien upon the property of a delinquent taxpayer. Subdivision (b) of section 1141 of the Tax Law provides that upon docketing of a tax warrant with the county clerk "the amount of such warrant so docketed shall become a lien upon the title to and interest in real and personal property of the person against whom the warrant is issued.”

We…