N.Y. Real Property Tax Law § 1137: Statute of limitations

§ 1137. Statute of limitations. Every deed given pursuant to the

provisions of this article shall be presumptive evidence that the

proceeding and all proceedings therein and all proceedings prior thereto

from and including the assessment of the real property affected and all

notices required by law were regular and in accordance with all

provisions of law relating thereto. After two years from the date of the

recording of such deed, the presumption shall be conclusive. No

proceeding to set aside such deed may be maintained unless the

proceeding is commenced and a notice of pendency of the proceeding is

filed in the office of the proper county clerk prior to the time that

the presumption becomes conclusive.