N.Y.C. Admin. Code § 11-1012: § 11-1012 Reserves.

In cases where the taxpayer has paid any tax under written protest stating in detail the ground or grounds therefor, or has applied for a refund and an order under article seventy-eight of the civil practice law and rules to review a determination adverse to the taxpayer on the taxpayer's application for refund, or has deposited the amount of tax assessed in connection with a proceeding under section 11-1009 of this chapter the commissioner of finance shall set up appropriate reserves to meet any decision adverse to the city.