N.Y. Suffolk County Tax Act § 63: Presumption of validity of tax

§ 63. Presumption of validity of tax. It shall be presumed that every

tax levied and assessment made is valid and regular, and that all the

steps and proceedings required by law were taken and had, until the

contrary shall be made to appear. Any action or proceedings commenced by

any person or persons to test the validity or regularity of any tax

levied or assessment made shall be commenced within two years from the

date of the receipt of the tax warrant by the town receiver of taxes.

The invalidity or irregularity of any tax or assessment shall not be

available as a defense to any action or proceeding commenced after the

expiration of two years from the delivery of such warrant as aforesaid,

or for the enforcement of any right or title, by virtue of any sale

thereunder, unless an action or proceeding to test the validity or

regularity of such tax or assessment shall have been commenced within

the time hereinbefore limited for commencing the same, and shall be

still pending, or such tax or assessment shall have been adjudged to be

irregular and invalid.