N.Y. Tax Law § 281: Statute of limitations not applicable

§ 281. Statute of limitations not applicable. 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, determine or enforce the collection of any tax or penalty

prescribed by this article, provided, however, that no such proceeding

or action shall be commenced after the expiration of ten years after a

tax became due or a penalty incurred, except that such proceeding or

action may be commenced at any time if the failure to pay the tax or

penalty was with intent, in any manner, to defeat or evade the same.