Where a taxpayer refuses or neglects to pay any tax assessed under the Act, and it has become necessary to seize and sell the property and rights to property (real and personal) of the taxpayer, the Director may request the Attorney General to commence an action in the Superior Court to enforce the State's lien upon the taxpayer's property or subject such property to the payment of the tax.
N.J. Admin. Code § 18:23-10.4