2006 New York Code - Reserves.

 
    §  11-2109 Reserves. In cases where the grantor or grantee has applied
  for a refund and has instituted a proceeding under article seventy-eight
  of the civil practice law and rules to review a determination adverse to
  him or her on his or her application for refund, the  comptroller  shall
  set up appropriate reserves to meet any decision adverse to the city.