2006 New York Code - Remedies Exclusive.

 
    §  11-812  Remedies  exclusive.  The remedies provided by this chapter
  shall be the exclusive remedies available to any person for  the  review
  of  tax  liability  imposed  by  this  chapter;  and no determination or
  proposed determination of tax or determination on  any  application  for
  refund  by  the  commissioner  of  finance,  nor any decision by the tax
  appeals tribunal or any of  its  administrative  law  judges,  shall  be
  enjoined  or  reviewed  by an action for declaratory judgment, an action
  for money had and received or by any action or proceeding other than, in
  the case of a decision by the tax appeals tribunal sitting  en  banc,  a
  proceeding  under  article  seventy-eight  of the civil practice law and
  rules; provided, however, that a taxpayer  may  proceed  by  declaratory
  judgment  if  the  taxpayer  institutes  suit within thirty days after a
  deficiency assessment is made and pays  the  amount  of  the  deficiency
  assessment  to  the  commissioner of finance prior to the institution of
  such suit and posts a bond for costs as provided in  section  11-810  of
  this chapter.