nited States by invoking a State law
limiting suits to recover taxes alleged to have been assessed illegally
to taxes paid at the time and in the manner provided by said law.[611]

Laches

Persons failing to avail themselves of an opportunity to object and be
heard, cannot thereafter complain of assessments as arbitrary and
unconstitutional.[612] Likewise a car company, which failed to report
its gross receipts as required by statute, has no further right to
contest the State comptroller's estimate of those receipts and his
adding thereto the 10% penalty permitted by law.[613]

Collection of Taxes

To reach property which has escaped taxation, a State may tax the
estates of decedents for a period anterior to death and grant
proportionate deductions for all prior taxes which the personal
representative can prove to have been paid.[614] Collection of an
inheritance tax also may be expedited by a statute requiring the sealing
of safe deposit boxes for at least ten days after the death of the
renter and obliging the lessor to retain assets found therein sufficient
to pay the tax that may be due the State.[615] Moreover, with a view to
achieving a like result in the case of gasoline taxes, a State may
compel retailers to collect such taxes from consumers and, under penalty
of a fine for delinquency, to remit monthly the amounts thus
collected.[616] Likewise, a tax on the tangible personal property of a
nonresident owner may be collected from the custodian or possessor of
such property, and the latter, as an assurance of reimbursement, may be
granted a lien on such property.[617] In collecting personal income
taxes, however, most States require employers to deduct and withhold the
tax from the wages of only nonresident employees; but the duty thereby
imposed on the employer has never been viewed as depriving him of
property without due process of law, nor has the adjustment of his
system of accounting and paying salaries which withholding entails been
viewed as an unreasonable regulation of the conduct of his
business.[618]

As a State may provide in advance that taxes shall bear interest from
the time they become due, it may with equal validity stipulate that
taxes which have become delinquent shall bear interest from the time the
delinquency commenced. Likewise, a State may adopt new remedies for the
collection of taxes and apply these remedies to taxes already
delinquent.[619] After liability of a taxpayer has be