2006 New York Code - Reserves.

 
    § 11-2209 Reserves. In cases where a taxpayer 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 such
  taxpayer on his or her application for refund, the commissioner of motor
  vehicles shall set up appropriate reserves to meet any decision  adverse
  to the city.