N.Y.C. Admin. Code § 11-1408: § 11-1408 Reserves.

In cases where the transferee or transferor has applied for a refund and has instituted a proceeding under article seventy-eight of the civil practice law and rules to review a determination adverse to the transferee or transferor on his or her application for refund, the comptroller shall set up appropriate reserves to meet any decisions adverse to the city.