N.Y. Tax Law § 207: Limitation of time

§ 207. Limitation of time. The provisions of the civil practice law

and rules relative to the limitation of time of enforcing a civil remedy

shall not apply to any proceeding or action taken to levy, appraise,

assess, determine or enforce the collection of any tax or penalty

prescribed by this article, and this section shall be construed as

having been in effect as of the date of the original enactment of the

corporation tax law, provided, however, that as to real estate in the

hands of persons who are owners thereof who would be purchasers in good

faith but for such tax or penalty and as to the lien on real estate of

mortgages held by persons who would be holders thereof in good faith but

for such tax or penalty, all such taxes and penalties shall cease to be

a lien on such real estate as against such purchasers or holders after

the expiration of ten years from the date such taxes became due and

payable. The limitations herein provided for shall not apply to any

transfer from a corporation to a person or corporation with intent to

avoid payment of any taxes, or where with like intent the transfer is

made to a grantee corporation, or any subsequent grantee corporation

controlled by such grantor or which has any community of interest with

it, either through stock ownership or otherwise. Nothing herein shall

affect any action or proceeding now actually pending to enforce the

collection of such tax or penalty from such real estate.