N.Y. Second Class Cities Law § 164: Right to review assessment or tax for local improvement limited

§ 164. Right to review assessment or tax for local improvement

limited. No action or proceeding to set aside, vacate, cancel or annul

any assessment or tax for a local improvement shall be maintained,

except for total want of jurisdiction to levy and assess the same on the

part of the officers, board or body authorized by law to make such levy

or assessment or to order the improvement on account of which the levy

or assessment was made. No action or proceeding shall be maintained to

modify or reduce any such assessment or tax except for fraud or

substantial error by reason of which the amount of such tax or

assessment is in excess of the amount which should have been lawfully

levied or assessed.