dissenting. As I understanding the ruling in State v. W. & A. R. Co., 136 Ga. 619 (71 S. E. 1055), it was not that taxes were not debts but only that a common-law action would not lie to recover them since a specific remedy for their collection had been provided. It was held in Citizens & Southern Bank v. State, 151 Ga. 696 (108 S. E. 161), that the provision for a specific remedy for the collection of taxes did not exclude other remedies and that the Supreme Court had gone no further than to hold that an action at laio will not lie in this State to collect taxes as a debt, and in that case an equitable remedy was authorized.
*680The tax commissioner is charged with the collection of taxes and is impliedly authorized to do whatever is necessary and proper to insure their collection in his- official capacity.. Code § 92-4901. See Code § 113-1212. The fact that a year’s support is a favorite'of the law and dictated by a very humanitarian public policy is irrelevant to the issue. The law does not intend for an- excessive year’s support to transfer the burden of taxes from the property set -aside as a year’s support: to other innocent taxpayers.. I dissent from the judgment of'reversal.