N.Y. Tax Law § 1140: Remedies exclusive

§ 1140. Remedies exclusive. The remedies provided by sections eleven

hundred thirty-eight and eleven hundred thirty-nine shall be exclusive

remedies available to any person for the review of tax liability imposed

by this article; and no determination or proposed determination of tax

or determination on any application for refund shall be enjoined or

reviewed by an action for declaratory judgment, an action for money had

and received, or by any action or proceeding other than a proceeding

under article seventy-eight of the civil practice law and rules.