In this tax appeal, the court is asked to determine whether the four-year limitation period governing the additional assessment of the Sales and Use Tax (SUT) applies to the issuance of a Notice of Finding of Responsible Person (Responsible Person Notice) for SUTs that a corporation has acknowledged it owed. A merchant collects SUTs and holds them in trust "as trustee for and on account of the State." N.J.S.A. 54:32B-12(a). Thus, an officer or responsible person of a business is held personally liable for these taxes when the business fails to remit them to the State. The court concludes that the Responsible Person Notice is a collection tool for a previously determined, fixed, and final tax liability assessed against the business and not an additional assessment. Therefore, the issuance of a Responsible Person Notice for liability of SUT is not subject to a limitations period. Accordingly, we affirm the Tax Court's order denying, in part, plaintiff Christopher Gill's motion for summary judgment and granting, in part, defendant Division of Taxation's motion for summary judgment.