2006 New York Code - Remedies Exclusive.

 
    §  11-2210  Remedies  exclusive.  The  remedies  provided  by sections
  11-2206 and 11-2208 of 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 motor
  vehicles  or 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 final determination by the commissioner of motor  vehicles
  or  a decision by the tax appeals tribunal sitting en banc, 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 motor vehicles prior to
  the institution of such suit and posts a bond for costs as  provided  in
  section 11-2206 of this chapter.