The taxes imposed by this subtitle and interest and penalties thereon from the time the same shall be due and payable until the same be paid shall be a personal debt due from the taxpayer to the State, recoverable in any court of competent jurisdiction in a civil action and the proceeds of any judgment so obtained shall be paid to the director. Such debt, whether sued upon or not, shall be a lien on all the property of the debtor except as against an innocent purchaser for value in the usual course of business and without notice thereof, and shall be preferred in any distribution of the assets of the taxpayer whether in bankruptcy, insolvency or otherwise. The director, whenever requested in writing and provided there is paid to him for the use of the State of New Jersey a fee of one dollar ($1.00) for each person for whom a certificate is requested, shall issue a certificate stating whether or not any such person is indebted to the State for any taxes, penalties, and interest under the provisions of this subtitle, and, if so, the amount thereof.
N.J.S. § 54:44-2