McLaughlin v. Laffoon Oil Co., 1968 OK 69, ¶ 28, 446 P.2d 603.Harvey v. Frizzell, 1950 OK 190, ¶ 0, 203 Okla. 424, 222 P.2d 752. ¶ 17 The parties reliance on only 12 O.S. 1981 § 95, or 12A O.S. Supp. 1992 § 3-118[ 12A-3-118](a), fails to take into consideration 12 O.S. 2001 § 101[ 12-101], which provides that partial payment extends or revives the statute of limitations and 12A O.S. 2001 § 1-103[ 12A-1-103], which states that the general statutes and case law of the state shall supplement the UCC. Although we have not discussed the statutory trifecta of 12 O.S. 1981 § 95, 12A O.S. Supp. 1992 § 3-118[ 12A-3-118](a), and 12 O.S. 2001 § 101[ 12-101], the Court of Civil Appeals has previously recognized that § 101 applies to the UCC and, because § 103 provides for general statutes to supplement the UCC, we agree.

Moreover, the statute of limitations commences to run on each item of an open account at the time that charge is entered in the account. Pitts v. Walker, 188 Okla. 17, 105 P.2d 760 (1940) and Harvey v. Frizzell, 203 Okla. 424, 222 P.2d 752 (1950). The statute of limitations may be revived as to the entire account, as in Garland, if a payment is made within the limitations period prior to commencement of the action and is made with the intent that it apply on the "balance due."

The rule in most jurisdictions is that partial payment on a debt may start the statute of limitations running anew where the payment is made voluntarily by a debtor under circumstances that warrant a clear inference that the debtor recognizes the whole debt to be subsisting and demonstrates his willingness or obligation to pay the balance of the debt. See Zapolsky v. Sacks, 191 Conn. 194, 464 A.2d 30 (1983); Himelfarb v. American Express Co., 301 Md. 698, 484 A.2d 1013 (1984); Castellano v. Bitkower, 216 Neb. 806, 346 N.W.2d 249 (1984); T.S. McShane Co. v. Dominion Constr. Co. 203 Neb. 318, 278 N.W.2d 596 (1979); Lew Morris Demolition Co. v.Board of Education, 40 N.Y.2d 516, 355 N.E.2d 369, 387 N.Y.S.2d 409, 10 A.L.R.4th 925 (1976); Randustrial Corp. v. Acme Distribution Center, 79 A.D.2d 862, 434 N.Y.S.2d 511 (1980); Whitley's Elec. Serv., Inc. v. Sherrod, supra; Harvey v. Frizzell, 203 Okla. 424, 222 P.2d 752 (1950); Graves v. Sawyer, 588 S.W.2d 542 (Tenn. 1979); J. Angell, Limitations of Actions at Law §§ 240-47 (6th ed. 1876); H. Buswell, The Statute of Limitations and Adverse Possession §§ 77-87 (1889); 1A A. Corbin, Corbin on Contracts § 217 (1963); 18 S. Williston, Law of Contracts §§ 2061-65 (3d ed. 1978); 1 H. Wood, Limitation of Actions §§ 96-116i (4th ed. 1916); 51 Am.Jur.2d Limitation of Actions §§ 360-90 (1970); 54 C.J.S. Limitations of Actions §§ 321-39 (1948); Restatement (Second) of Contracts § 82 (1981); Annot., 45 A.L.R.2d 967 (1956). Thus, payment under compulsion of legal process is not voluntary. 51 Am.Jur.2d Limitation of Actions § 367 (1970).

" In the case of Harvey v. Frizzell, 203 Okla. 424, 222 P.2d 752, 754, we said: "We are of the opinion that the trial court's finding that the defendant's final payment was simply a payment upon a general balance due was correct.