2006 New York Code - Remedies Exclusive.

 
    §  11-2110  Remedies  exclusive.  The  remedies  provided  by sections
  11-2107  and  11-2108  of  this  chapter  shall  be  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  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 a proceeding in
  the nature of a certiorari proceeding under article seventy-eight of the
  civil practice law and rules; provided, however,  that  a  taxpayer  may
  proceed  by  declaratory  judgment  if  he or she 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 11-2107 of this chapter.