N.Y. GCM Law § 10

§ 10. Limitations of time. The provisions of the civil practice law\nand rules relative to the limitation of time of enforcing a civil remedy\nshall not apply to any proceeding or action taken to levy, appraise,\nassess, determine or enforce the collection of any tax or penalty\nprescribed by this part, provided, however, that as to real estate in\nthe hands of persons who are owners thereof who would be purchasers in\ngood faith but for such tax or penalty and as to the lien on real estate\nof mortgages held by persons who would be holders thereof in good faith\nbut for such tax or penalty, all such taxes and penalties shall cease to\nbe a lien on such real estate as against such purchasers or holders\nafter the expiration of ten years from the date such taxes became due\nand payable. The limitations herein provided for shall not apply to any\ntransfer from a corporation to a person or corporation with intent to\navoid payment of any taxes, or where with like intent the transfer is\nmade to a grantee corporation, or any subsequent grantee corporation,\ncontrolled by such grantor or which has any community of interest with\nit, either through stock ownership or otherwise.\n