N.Y.C. Admin. Code § 11-2709: § 11-2709 Reserves.

In cases where the person or persons liable for the vault charge imposed by this chapter 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 him or her on his or her application for refund, the comptroller shall set up appropriate reserves to meet any decision adverse to the city.