N.Y. EPT Law § 2-1.14

§ 2-1.14 Right to recover state estate and gift taxes where decedent\n retained interest\n (a)(1) If any part of the gross tax estate on which tax has been paid\nconsists of the value of property included in the gross estate by reason\nof section two thousand thirty-six of the internal revenue code\n(relating to transfers with retained life estate), the decedent's estate\nshall be entitled to recover from the person receiving the property the\namount which bears the same ratio to the total tax under this chapter\nwhich has been paid as\n (A) the value of such property bears to\n (B) the taxable estate.\n (2) Paragraph one shall not apply if the decedent otherwise directs in\na provision of his will (or a revocable trust) specifically referring to\nthis section.\n (b) For purposes of this section, if there is more than one person\nreceiving the property, the right of recovery shall be against each such\nperson.\n (c) In the case of penalties and interest attributable to the\nadditional taxes described in subsection (a) of this section, rules\nsimilar to the rules of subsections (a) and (b) of this section shall\napply.\n (d) No person shall be entitled to recover any amount by reason of\nthis section from a trust to which section six hundred sixty-four of the\ninternal revenue code applies (determined without regard to this\nsection).\n