N.Y. Tax Law § 278: Effect of failure to pay tax

§ 278. Effect of failure to pay tax. No transfer of certificates

taxable under this article made after June first, nineteen hundred and

five, on which a tax is imposed by this article, and which tax is not

paid at the time of such transfer shall be made the basis of any action

or legal proceedings, nor, except in a proceeding under articles ten-c

and twenty-six of this chapter, shall proof thereof be offered or

received in evidence in any court in this state.