2006 New York Code - Statute Of Limitations Not Applicable.

 
    §  281.  Statute of limitations not applicable.  The provisions of the
  civil practice law and rules relative  to  the  limitation  of  time  of
  enforcing  a  civil  remedy  shall not apply to any proceeding or action
  taken to levy, determine or enforce the collection of any tax or penalty
  prescribed by this article, provided, however, that no  such  proceeding
  or  action  shall be commenced after the expiration of ten years after a
  tax became due or a penalty incurred, except  that  such  proceeding  or
  action  may  be  commenced  at any time if the failure to pay the tax or
  penalty was with intent, in any manner, to defeat or evade the same.