2010 New York Code
RPA - Real Property Actions & Proceedings
Article 2 - (201 - 241) GENERAL PROVISIONS GOVERNING REAL PROPERTY ACTIONS
203 - Judgment in action adversely affecting the title, interest or claim of the state based upon tax deed.

§  203.  Judgment in action adversely affecting the title, interest or
  claim of the state based upon tax deed.  In  any  action  affecting  the
  title,  or  the  possession, enjoyment or use of, real property in which
  one of the parties is the state, any judgment that may adversely  affect
  the  title,  interest  or claim of the state based upon a tax deed shall
  provide in effect as follows:
    1. That the state shall have a lien upon such real  property  or  part
  thereof  described  in  such  tax  deed, prior and superior to all other
  liens, (a) for the amount of the unpaid taxes not  adjudged  illegal  in
  such  action  for which such real property was sold or liable to be sold
  in the first instance and for which such tax deed was  issued,  together
  with  fees, charges and interest; (b) for the amount of the unpaid taxes
  not adjudged illegal in such action for which  such  real  property  was
  subsequently  sold or liable to be sold, together with fees, charges and
  interest; (c) for the amount of all taxes, fees and charges admitted  or
  paid  by  the  state upon such real property to the date of the entry of
  such judgment, together with interest thereon  from  the  date  of  such
  admission  or  payment. In the determination of the amount of such lien,
  establishment of payments of taxes on said real property by the adjudged
  or admitted owner of the property during any of the same years in  which
  payments  were also made by the state shall reduce the lien of the state
  by the larger of the two tax payments for each of the years affected  by
  duplicate payments, and in the event that wholly identical areas are not
  affected  by  the  duplicate  payments  the  court  shall  have power to
  apportion and adjust the amount of the lien as equity may require.
    2. That the state may foreclose  such  lien  as  a  mortgage  on  real
  property  is  foreclosed,  provided  such  lien remains unpaid after the
  expiration of one year from the entry of such judgment.
    The remedy provided by this section for recovery of tax payments shall
  be in addition to any other remedy now or hereafter available in law  or
  in equity.