2006 New York Code - Reserves.

 
    §  11-2410  Reserves.  In  cases  where the 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 city comptroller
  shall set up appropriate reserves to meet any decision  adverse  to  the
  city.