2019 New York Laws
RPA - Real Property Actions and Proceedings
Article 9 - Action for Partition
947 - Judgment Affecting State Tax Claim.

§  947.  Judgment  affecting  state  tax  claim.  A judgment affecting
  adversely 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 land 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.