2006 New York Code - Reserves.

 
    § 11-1012 Reserves. In cases where the taxpayer has paid any tax under
  written protest stating in detail the ground or grounds therefor, or has
  applied  for  a  refund  and an order under article seventy-eight of the
  civil practice law and rules to review a determination  adverse  to  the
  taxpayer  on the taxpayer's application for refund, or has deposited the
  amount of tax assessed in connection with  a  proceeding  under  section
  11-1009  of  this  chapter  the  commissioner  of  finance  shall set up
  appropriate reserves to meet any decision adverse to the city.