Section 1414. Proceedings to recover tax

(a) Whenever any person shall fail
  to  pay  any  tax,  penalty  or  interest  imposed  by this article, the
  attorney general shall, upon the request of the commissioner of taxation
  and finance, bring or cause to be  brought  an  action  to  enforce  the
  payment  of  the same on behalf of the state of New York in any court of
  the state of New York or of any other state or of the United States.
    (b) As an additional or alternate remedy, the commissioner of taxation
  and finance may issue a warrant, directed to the sheriff of  any  county
  commanding  him  to levy upon and sell the real and personal property of
  any grantor or grantee liable for the tax, which may be found within his
  county, for the payment of the amount  thereof,  with  any  penalty  and
  interest,  and  the  cost  of  executing the warrant, and to return such
  warrant to the commissioner of taxation  and  finance  and  to  pay  the
  commissioner  the  money  collected  by virtue thereof within sixty days
  after the receipt of such warrant. The sheriff shall  within  five  days
  after  the  receipt  of  the  warrant  file with the county clerk a copy
  thereof, and thereupon such clerk shall enter in the judgment docket the
  name of the person mentioned in the warrant and the amount of  the  tax,
  penalty  and  interest for which the warrant is issued and the date when
  such copy is filed. Thereupon the amount of  such  warrant  so  docketed
  shall  become  a  lien  upon  the  title to and the interest in real and
  personal property of the person against whom the warrant is issued. Such
  lien shall not apply to personal property unless such warrant  is  filed
  in  the  department  of  state.  The sheriff shall then proceed upon the
  warrant, in the same manner, and with like effect, as that  provided  by
  law in respect to executions issued against property upon judgments of a
  court  of  record  and for services in executing the warrant he shall be
  entitled to the same fees, which he may collect in the same manner.   In
  the  discretion of the commissioner of taxation and finance a warrant of
  like terms, force and effect may be issued and directed to  any  officer
  or  employee  of  the division of taxation, and in the execution thereof
  such officer or employee shall have all the powers conferred by law upon
  sheriffs, but shall be entitled to no fee or compensation in  excess  of
  the  actual  expenses  paid  in  the performance of such duty. Upon such
  filing of a copy of a warrant, the commissioner of taxation and  finance
  shall  have the same remedies to enforce the amount due thereunder as if
  the state had recovered the judgment therefor.